[dapperdrake]

The return value depends on control flow ("obvious", please bear with me):

With "goto" the cleanup-up can jump anywhere. With "defer" the cleanup cannot really jump anywhere. It is easier to mentally stick to simply cleaning up in a common sense way. And taking care of multiple "unrelated" clean-up steps is "handled for you."

(Attacks on this sometimes approach complaints about lack of "common sense".)