Hi @Brian W,
The cause may be the size of the recoverable items has reached its limit.Please refer to this link: Recoverable Items mailbox quotas
You can use the following cmdlet in Exchange Online to check the size of the recoverable items folder:
Get-MailboxFolderStatistics <username> -FolderScope RecoverableItems | FL Name,FolderAndSubfolderSize,ItemsInFolderAndSubfolders
If this is the case, please follow this link to delete items from the recoverable items folder and see if it can help with this issue:
Clean up or delete items from the Recoverable Items folder in Exchange Online
If the mailbox is on hold, please refer to this link:
Delete items in the Recoverable Items folder of cloud-based mailboxes on hold
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