The qmail spec describes queuing and delivery in a filesystem-safe manner.
Perhaps you should examine the section discussing the various problems with file systems. ZFS is hardly immune from these problems.
Origins: one starts out with proprietary developed functionality and with tons of money in a skunkworks project, using a consolidated team of developers mainly within one company through the fs development and stabilization; the other starts with an idea in a research paper (not called btrfs then because it wasn't an implementation), slow recruitment that'd eventually involve dozens of major companies, and is on a split stabilize and feature development track.
And then if you go back to look at features (commands in particular) in more detail there are some big differences that may or may not affect specific workflows. e.g. btrfs snapshots are unique and independent file trees, in effect there's no distinction between the original and snapshot, both are read-writable, modifying one doesn't affect the other, either can be deleted without affecting the other (ZFS has a distinct parent-child relationship between filesystems, clones, snapshots). Growing btrfs volumes by adding then (at some point balancing, which may be optional depending on the utilization and layout) is a lot easier and faster than ZFS. ZFS offers raid7 (3 parity drives), Brfs does not. Btrfs offers online defragmentation, ZFS does not. ZFS is more stable for $reasons. Really even ext4 and XFS are considered more stable still, although I hesitate to say Btrfs is not stable or unstable. I'd say Btrfs is earning trust, where the others have earned it (with very edge case exceptions, and there simply are more such edge cases for Btrfs still being found and fixed)
So they're actually quite different.
I've been a heavy mail user for years... Never encountered data loss due to file system problem, and honestly I can't think of a time in the last decade where anyone I'm acquainted with has. (And I ran a very large mail system for a long time)
Hell, I've been using OSX predominately for years now, and that garbage file system hasn't eaten any data yet!
There are problems, even fundamental problems, but if someone is literally unable to use any mail client, you need to look at the user before the file system.
20 years ago Mac OS crashed often, and had a file system not designed to account for that. OS X even shipped with non-journaled HFS+. It was only into the 3rd major release of OS X that journaling appeared. Data corruptions, I feel, dropped massively, because the OS didn't crash nearly as often, but did still crash. In the last 4-5 years I'd say I get maybe one or two kernel panics per year on OS X, which is a lot less than I get on Linux desktops. But even still on Linux desktops, I can't say when I've seen file system corruption not attributable to pre-existing hardware issues.
Mail servers and clients (MTAs and MUAs) have been using Maildir format to escape this problem since 1996.
Filesystems have evolved. ZFS has been available for ten years.
If you take your data seriously, you do need to make informed choices. But this article isn't targeted at people who won't know about Maildir and ZFS.
The section about relative data loss failures between various applications is great. Again, careful choices: SQLite and Postgres.