After investigating, I found this to be DEFAULT behavior in this scenario:
1) you are sending to an external contact defined in Exchange Management Console
2) the contact you are sending to does not use Outlook
To resolve it, you need to edit the properties of the contact. There is a field on the general tab for "Use MAPI rich text format." It should be changed from "use default settings" to "never"

You can also fix this universally for all users (by changing the default settings) in EMC > Organization configuration > hub transport. On the Remote Domains tab, right click on Default and choose Properties. Click on the message format tab and choose "Never use"
