sbrk grows linearly, and if anything is mapped in the way it fails. mmap can map anywhere there's space as it is not restricted to linear mappings. So, you'd better hope a mapping doesn't randomly land there and run you out of space.

It's not a failure but relatedly as sbrk is linear, you also don't really have a reasonable way to deal with fragmentation. For example, suppose you allocate 1000 page sized objects and then free all but the last one. With an mmap based heap, you can free all 999 other pages back to the OS whereas with sbrk you're stuck with those 999 pages you don't need for the lifetime of that 1000th object (better hope it's not long lived!).

Really, sbrk only exists for legacy reasons.