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Could be crud clogging up the lifter's oil-holes.
Remove each one, turn upside-down and push on the button in the middle.
If you've recently turned off the car, they should all be pumped up and hard.
The clogged/bad lifter will be the one with the soft squishy button you can push into the body.
You can try soaking it in solvent like acetone/lacquer-thinner and push the button up & down repeatedly to pump the solvent into the lifter. This may dissolve the crud inside and you'll see a brown cloud seeping out of the lifter into the surrounding solvent. Then repeat the pumping with the lifter in oil to see if it fills and locks.
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