There is substantial interest in the use of machine learning (ML)-based techniques throughout the electronic computer-aided design (CAD) flow, particularly methods based on deep learning. However, while deep learning methods have achieved state-of-the-art performance in several applications, recent work has demonstrated that neural networks are generally vulnerable to small, carefully chosen perturbations of their input (e.g. a single pixel change in an image). In this work, we investigate robustness in the context of ML-based EDA tools -- particularly for congestion prediction. As far as we are aware, we are the first to explore this concept in the context of ML-based EDA. We first describe a novel notion of imperceptibility designed specifically for VLSI layout problems defined on netlists and cell placements. Our definition of imperceptibility is characterized by a guarantee that a perturbation to a layout will not alter its global routing. We then demonstrate that state-of-the-art CNN and GNN-based congestion models exhibit brittleness to imperceptible perturbations. Namely, we show that when a small number of cells (e.g. 1%-5% of cells) have their positions shifted such that a measure of global congestion is guaranteed to remain unaffected (e.g. 1% of the design adversarially shifted by 0.001% of the layout space results in a predicted decrease in congestion of up to 90%, while no change in congestion is implied by the perturbation). In other words, the quality of a predictor can be made arbitrarily poor (i.e. can be made to predict that a design is "congestion-free") for an arbitrary input layout. Next, we describe a simple technique to train predictors that improves robustness to these perturbations. Our work indicates that CAD engineers should be cautious when integrating neural network-based mechanisms in EDA flows to ensure robust and high-quality results.