I think it has more to do with platform limitations.
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No, it has to do with
mental limitations of the SDEs in WinPRT at MSFT. If the system is low on memory the FilePicker should reduce its memory usage (show text instead of thumbnails, etc.). If it still runs out of memory, how about this concept:
return an OUT_OF_MEMORY error!. It's ok, sometimes things fail. You never design an API so that the rare error case metastasizes throughout third party code ... yet that's exactly what they've done here.
Design errors like this, where the exceptional case rules the roost, happens when there are too many cooks in the kitchen. You have a bunch of devs in a room and they all chime in with what could go wrong. Rather than design something that works 99.9% of the time (returning a freaking filename), the developer implementing the API is saddled with dealing with ninety-nine 0.1% cases that won't ever happen and comes up with a monstrosity. It's a failure of middle management to go to the dev and say "make it work and fail out on rare cases". Been there, done that.