Error: A constituent can only have one primary phone - when committing a constituent update batch

When committing a constituent update batch, a user may receive one of the following errors:

A constituent can only have one primary phone.
The UPDATE statement conflicted with the CHECK constraint "CK_PHONE_ PRIMARYCOUNT".  The conflict occurred in database "BBTAS_Phase2", table "dbo.PHONE'.

This occurs even when each constituent in the batch only has one phone number on their record that is already marked as primary.
Download and install the latest patch, which contains all fixes from previous patches. If you are running an older version, download and install the latest version and then the patch. 

Environment

 2.94.1524, patch 60
 2.94.1524, patch 76 ; 3.0.516, Service Pack 2

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