Like any aspect of writing software, how you approach the problem effects the complexity of the final product. If someone doesn't make a habit of handling OOM, then of course their solutions are going to be messy and complex; they're going to "solve" the problem in the most direct and naive way, which is rarely the best way.

For example, unless I have reason to use a specialized data structure, I use intrusive list and RB-tree implementations, which cuts down on the number of individual allocations many fold. Once I allocate something like a request context, I know that I can add it to various lists and lookup trees without having to worry about allocation failure. Most of my projects have more points where they do I/O operations than memory allocations. Should people just ignore whether their reads or writes failed, too?