Frequently the easiest path to perform a complex query with an ORM results in N+1 performance disasters. The inevitable retort is something like "but the ORM has better ways to do that." Of course it does; ORM implementers aren't incompetent. The key word is "easiest," meaning the ORM user doesn't have to spend time learning anything beyond simply chaining method calls. In production such work goes haywire when resolving some related entity causes tens of millions of round trips.

Without an ORM the easiest path is to write a single join, giving the database optimizer a fair shot at correctly optimizing the query, including over time as the database evolves. Again, yes an ORM can encapsulate the equivalent query. Guess what; for every time these ORM capabilities are actually utilized there are probably hundreds of expediently written N+1 queries because the programmer either didn't know better or was indifferent.

To a pragmatic mind this is the inevitable outcome when a tool makes the inefficient solution the easiest thing to do.