I don't see anything wrong in principle with "account lock out" provided that it doesn't affect existing sessions and provided that you can just ask the site to send an email with a token to reset your password. Spammers can lock a user out, so what. Minor inconvenience. If it's happening a lot to the same user and it's also affecting the user negatively, something extra could be done to minimize lockouts for the actual user (who should be easy to detect by the server through logs and a premise the user isn't trying to hide).
Spammers are able to flood you with "forgot your password?" emails, too. I don't know how often they do it. I had my first wave in after 7 years of the same email just a few months ago mostly from old sites I forgot I even had accounts on.
I'm not really a fan of the exponential backoff idea proposed earlier above, I'd sooner go with the "X tries, then wait" approach. The lockout time should not be more than 24 hours, ideally less. Though one could also set the lockout period to expire when the user's session automatically expires, if there's a current one, but that may be too clever.
I feel that there are really two pieces of advice to give on dealing with spammers for the general case... Advice for low-traffic sites and advice for high-traffic sites. I don't have any advice with high-traffic sites since I have no experience with spam at that level (and by high-traffic I mean thousands to millions of uniques per hour), though I don't think the status quo is good enough. With low-traffic sites spam behavior is easy to detect and create a custom solution against. Custom solutions are often better than the popular stuff just by virtue of not having anyone targeting them specifically, and even if that's the case it's still easier to cat-and-mouse if the main options against spam aren't acceptable. Something as dead-simple as loading your form with javascript (or dynamically changing the URL endpoint when the submit button is clicked to something different than what's reported by the form's html attribute...) stops a lot of bots regardless of a captcha, even though you sacrifice the Lynx users. And in my own anecdotal experience I've had more success (less spam bots getting through and leaving a message) with a captcha like "Please join these two "words" together (without spaces): taeiswovd and brhpugqc" than with ReCaptcha even though it'd take less than a minute to add a parser for mine in a bot program. I used to use an arithmetic question but even the dumb bots are on to that one these days--at least the ones after my comment boxes. (I don't even think they added, they just tried numbers 0-99 and sometimes got lucky.)
Why? The poor soul answering support calls likely didn't make this policy and cannot do anything to change it. I guess if you like just unloading anger at some unempowered person who has the responsibility of taking a bunch of crap without reacting in turn then this is a good idea. Otherwise it is more useful to take your business elsewhere, and if you must try finding someone to complain towards that might actually be able to encourage change.
And as a complete aside: given the attitude PayPal phone representatives have displayed, they seem to deserve it personally, too.
Of course, if one ip is making too many requests, it gets blocked or captchaed
IP blocks can be countered in other ways (botnets, tor, etc).
I'm not saying it's a bad idea though, there doesn't seem to be any downside apart from the book-keeping required. You could probably start with a higher delay (5 to 10 seconds seems very reasonable) and increase it to several minutes. But please don't make it 24 hours after 3 failed attempts, which happened to me when I tried to order train tickets online and forced me to make a trip to a physical ticket vending machine.