linmix, I didn't see a flag for free space instead of used space. Here is the complete output of df -h:
Filesystem Size Used Avail Use% Mounted on
/dev/sda2 17G 1.1G 15G 7% /
/dev/sda1 99M 14M 80M 15% /boot
none 62M 0 62M 0% /dev/shm
/dev/hdc1 170G 170G 0 100% /movies
/dev/hda1 230G 21G 207G 9% /data
There's only about 1.7GB of data that was previously on the drive under NTFS that won't fit now under ext3. Perhaps the 1.7GB difference has to do with the 1% reserved-blocks-percentage that's still set? Now that I calculate it out, it's exactly 1%. So I guess I answered my own question...
lol Thanks for everyone's reply.