On the other hand, disk electonics failures, disk controller failures, backplain failures, all do happen. Frequently. To me. (Well, more frequently than I'd like), and when they occur intermittently, these classes of failures will produce on-disk corruption, but that ZFS can withstand, even without ECC. So I would gladly take ZFS's protection against these, even at the risk of whatever it is that a memory error might produce.
Lastly, consider that if the data is important enough to warrant worrying about memory errors, it's important enough to have backups.
I've had a ZFS volume get very thoroughly trashed though by bad writes and still been able to recover data from it (back in the foolish days before ZFS-on-Linux when I had OpenSolaris in a VirtualBox VM with real disks, and something happened that randomly nuked blocks all over one of the filesystems. Interestingly: just the one FS. I had a whole bunch and others were untouched).
You might want to recover at least some files from a badly damaged FS if it is your home server with a baby photos, but would you really do that, if it was accounting of your company and not restore from a backup instead?