ESPHome Bluetooth proxies release devices left attached to a stalled controller session when a new connection replaces it. A peripheral that announces itself only while idle can otherwise remain undiscoverable until the proxy restarts.
J. Nick Koston tested the failure with an ESP32 proxy and a peripheral that stops advertising while connected. Replacing the frozen client releases the link, allowing the new client to reconnect. Re-subscribing from the same client keeps its existing links.