Since I've started trying the DVR functionality I enabled "delete" capability on my Plex server. On my 4th generation Apple TV when I select a TV episode, press and hold the touch surface and get the menu which includes delete, the episode title above the menu is not the episode title of the episode I selected. Typically it's the "previous" episode, i.e. the one to the left in the grid. This is in the "Recently Added" grid.
The one time this worked correctly was when I watched an episode and then deleted it immediately. In that case, for some reason, the correct episode title appeared above the menu.