I don't have it and it can't be the cause of this.
If an app would leak memory I would see it in the top.
As my numbers show there is plenty of memory, it didn't enough swap seriously.

It looks to me either like a bug or a per app limitation.
I have just started a gazillion of apps and the mem usage shot upwards, still I didn't encounter the error.
It only happens in modest and for a certain email.