Emacs has always been written in Lisp, and it's possible for badly written code to make it lock up. Not a new complaint on low RAM machines where the gc and paging interact badly. But you need very low RAM by today's standards.
Carefully worded with "more often" because I knew emacs was an outlier. I was never an emacs person myself so I don't know it first hand, but in do know people used to call it a resource hog a long time ago.