I believe this would be more related to something like memoizing a DOM structure in a "Live" listener that is later removed from the DOM but not garbage collected due to the reference in the event listener. As the poster mentioned, developer error -- not a fundamental language or browser implementation flaw.
If a language or browser implementation can't reclaim this unused memory thus creating a memory leak, that arguably is a flaw. It's literally a DoS attack vector that can be exploited by the untrusted scripts that run in the browser sandbox.
