Restricting Edit based on Issue Status
JIRA 3.2 ensures that issues cannot be bulk edited if they cannot be edited normally due to their workflow status. The default workflow restricts issues in the Closed status from being edited.
A new property - jira.issue.editable - has been added that allows the administrator to specify which statuses/steps within a workflow are editable. The administrator can set the flag to be false for a given status - any issue assocaited with the workflow in this status will not be editable or bulk editable.
An example can be found in the default workflow - the Closed status has the property key set to false - restricting the ability to bulk edit any issue in this status.
In order to change this behaviour, it is necessary to copy and edit the default workflow and associate your issues with the new workflow.