If so, the result of the query would be identical but the second one would likely have performance problems given the category_id filter is not being applied at the point where bar is joined. A clever database engine might find an optimisation but I wouldn't count on it.

This illustrates the subtle problem that ORMs can introduce - all logical tests pass but issues emerge over time. I found that typically every ORM based problem was resolved by rewriting it using SQL.

I used to use ORMs extensively, but my philosophy now is that you can make simple queries by using a query generator (i.e. connection.GetByID("MyTable", 100)) and complex queries have to be written by hand. I would not choose to use an ORM again.