Create a directory in Downloads with a symlink in it.  In my case, I got this when I unpacked a tgz file.

cd /home/chronos/user/Downloads
mkdir testdir
cd testdir
touch file.txt
ln -s file.txt link

Open FileManager and delete testdir.  Error is shown 'An error occurred.  Some items may not have been deleted'  file.txt is deleted, but link and dir cannot be removed.