Orinoco_cs module won't unload in 2.5.70

[Gregory Maxwell]

Kernel 2.5.70 (and 2.5.69-mm8 before it) on my Dell Latitude C840 is
unable to unload the orinoco_cs driver.

I get the following message over and over again while the rmmod hangs:
unregister_netdevice: waiting for eth1 to become free. Usage count = 1

Even after ifconfig downing the interface..

This is quite annoying because the driver doesn't survive suspend and I
can't cleanly shutdown. :)

Suggestions?