I have a standard split view controller, with a detail view and a table view. Pressing a button in the detail view can cause the an object to change its placement in the tab
I am doing the same thing in my application (transient property in the sectionNameKeyPath) and am not seeing the problem you are experiencing. I am testing this on iOS 4.2.1... There is a known bug where you cant trust any of the FRC delegate callbacks in iOS 3.X, you have to do a full [tableView reloadData] in the controllerDidChangeContent: message. see the FRC documentation
I have tested going from an existing section with another entry in it to a nonexistent section as well as from a section with only one row to another nonexistent section.