Update: It still comes out. Did it again today. So putting a small amount of tension on the trigger spring adjustment nut didn't change it.
I load each shot deliberately. Bolt up, bolt back, stop and check to see that the case really ejected and the next cartridge is lined up, bolt forward, bolt down, fire, repeat. I flip it briskly but not violently back because I want to be sure the spent cartridge ejects cleanly. I don't really grip it but don't think I should have to (somebody please correct me if I'm wrong). One time today, the bolt just dropped back out of the barrel and was stopped by my hand.
The rifle was freshly cleaned, shooting beautifully. I shot 100-125 rounds (all target quality and subsonic - nothing overpowered) and it happened once. Any ideas?