According to the documentation, the Android kernel is missing quite a few of the kernel features needed by LXC.
Perhaps in the future with Docker 1.x, it might be possible to write a plugin that uses Android features instead of LXC. But for now, you would need to build a custom Android kernel and then build LXC for it.
There are some people actually working on that, and Stéphane Graber has a good summary of the difficulties on his blog.