Marist have done some research and think they know why:
Cell Phones
Pollsters mostly call people on land lines, i.e. older people. Older people tend to vote conservative
"In Florida, Romney is +3% with landline voters, but Obama is +23% with cell phones."
5/30:Don’t Cell Out!
It should be the battle cry of all pollsters and poll watchers interested in accuracy when it comes to presidential polling. The problems of reaching cell phone only respondents are well documented. But, measurements of the Obama-Romney horse race that rely solely on landline households do so at great peril.
Check out the results from the recent NBC News/Marist Polls of swing states. In Florida, Romney is +3% with landline voters, but Obama is +23% with cell phones. In Virginia, it’s pretty much the same… Romney +1% with landlines, Obama is +18% among cells. Owing to his wider lead in Ohio, Obama is +4% with landline voters but is also +9% with the cell phone electorate.
Two final comments on this issue of methods: First, there’s no doubt that Obama’s advantage with cell phones has a lot to do with younger people dominating the cell phone only electorate. But, the under 30 aged voters made the difference in 2008. It would be a pollster gamble to undercount them this time. Second, this discussion has been only about telephone surveys with live interviewers. Robo-polls which also exclude cell phone households are an entirely different polling battlefield.
The bottom line: cell phone only households need to be included in all accurate attempts at public opinion measurement. For campaign 2012, it’s not a choice, it’s a necessity.
The other thing that has not been addressed is the political makeup of people prepared to sit through a poll. Many (most?) people hang up on pollsters. The people who don't are likely to be more opinionated, are they more likely to be conservative? I don't know but I would like to ...