This began as a mistake in the Layouts and Rendering in Rails guide: Layouts and Rendering in Rails — Ruby on Rails Guides
The author expected two layout calls in a controller to have their behaviour chained together.
I thought that made a lot of sense, so instead of a patch for the docs, I made a patch for action_controller/layout.rb with accompanying tests.
Seems like an intuitive addition: #2162 layout chaining - Ruby on Rails - rails
Cheers, Jason King