Is there a decent air flow in that case? I doubt it. You can put in/on a fan, but if there are no other ventilation holes to enable some kind of airflow, then all the fan does is trying to suck the heat out. That's not very efficient.
yes, because of this inefficent i use overpressure for the pi, much better cooling. And without case ~60°C, with case+fan ~37*C.
I don't know your old case, but that could be the issue. New shiny metal case -> problem solved?
I hope, as the problem is random i still testing, but looks good.