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bleIncorrectMode returned from GAP_TerminateLinkReq

after successfully connecting to my peripheral device, i later call GAP_TerminateLinkReq() with the connectionHandle (==0) returned earlier upon establishing the link....

the function returns bleIncorrectMode (0x12)  suggesting something is "not setup properly"....

i am able to successfully establish/terminate links with BTool, using the same peripheral device; it's only when i attempt to terminate the link programmatically that i have this issue....

what in general are some symptoms of this return code -- specifically in this context....