I got this problem just now for the second time. Reading a book I bought from the Sony Library (with DRM), put in a bookmark to swap to another book (one I'm writing, no DRM), then decided "nah, go back to the first one", but when I tried to reopen the DRM book I got the DRM message. There was no shutdown/sleeping involved, just exiting a DRM book, going into a non-DRM book, then trying to go back to the first one.
I resolved it by plugging my PRS-650 into the computer and firing up Sony Connect, then ejecting it. But by doing so, I lost my bookmark for the book (I didn't have any notes in the book, not sure if I'd have lost those also).
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