Doc ID : KB13814! That is NOT a good thing, regarding Application Switcher. One would figure that non system critical apps would be forced quit instead of the memory leak. Maybe the oldest (non system)app that hasn't been interfaced by the user regardless of new data downloaded should be closed.
This is just one of the reasons that RIM should invest in a HUGE order of more RAM to imbedd into their HH's. Start off with 96MB on the low to mid-range devices, then onto 128MB for the high-end strictly corporate marketed devices (like the 8800 series).