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It's entirely possible that the bolt was over-torqued by whoever installed it last. Over-torque will start to pull and break the threads but leave them "intact" enough to hold until disturbed next time (this gives aparticular feedback to the wrench turner at the time as it feels like it's slipping- an awful sensation). Once the next guy removes it and goes to tighten it, full torque can't be achieved before the threads pull all the way out and are "stripped".
Sad truth is that technicians rarely use torque wrenches. Unfortunately in a rushed, volume-driven dealership environment techs routinely omit extra steps in order to flag more hours and keep up with production expectations.
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