I don't see how it is possible. I just now tried to. Had a closed case and found the transaction in paypal and tried to file case and see if it would let me. It gave me the big red box saying "sorry there's a problem, you already filed a case, go to the ebay resolution center". So I don't know how your buyers are getting around it.
On a side note, I do have a case open with paypal and it also shows up in my ebay resolution center. So again, I don't see how your buyer is getting around that.
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