From a qmail log, trying to send a 1204 byte mail.
2002-07-31 21:16:05.536651500 delivery 1500: deferral: Connected to 126.96.36.199 but sender was rejected./Remote host said: 452 Out of memory/
It's fair to run out of memory; but not on a 1KB mail. And not repeatedly.
$ host 188.8.131.52 Name: mc2.law16.hotmail.com