A few years ago there was a rash of fraudulent state tax returns filed that took advantage of the fact that most states had weaker security procedures than the federal government, scammers would file many state returns using stolen or fake information without filing a matching federal return. Even though the states should have taken a significant amount of blame for the problem (in my opinion), most of the blame went on the software companies instead.
One result is that you now can't e-file a state return unless you also e-file a federal return. The limit on the number of state e-files may be another result of the same situation. But that's just a guess.
