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It is working as designed. The SourceSafe action wraps the VSS command-line program (ss.exe), which unlike the VSS Explorer, doesn't distinguish between checked-out vs. non-checked-out local writeable files when getting (which is reasonable since it doesn't make sense to prompt the user during an automated operation). It also will return a non-zero exitcode on get if any of the local files specified are writeable.
For automated builds, it's usually a good idea to use the Replace option on get (overwriting any local writeable files) to ensure a consistent build. If you do have local checked-out files, make sure to always get non-checked-out files read-only and use the 'Skip' option when getting latest to prevent the checked-out files from being replaced (marking the get step to ignore failure).
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