This problem has been documented on Github in the following issues.

https://github.com/facebook/react-native/issues/1831

https://github.com/facebook/react-native/issues/4728

https://github.com/facebook/react-native/issues/4179

https://github.com/facebook/react-native/issues/8607

It looks to crop up for some ListViews, but not all within an app. However, when it does show up it seems consistent.