My theme is one of those.  

We have that problem with other error messages also I think?

Mihai and I talked about this also.  If the user clicks submit because they didn't see the message, then they get the standard shipping quotes message at the top of the screen.  

I also recall a past discussion about the checkout error handling instractructure being somewhat richer in theme engine 2.0.  Might not be something we have to rototill right now?