Very true. I'm constantly running into code that wasn't refactored because my predecessors were too scared of introducing regressive errors in the process.
"I would optimize this algorithm but I don't want to bother with 4 rounds of code review."
If only. More of a "I don't want a dressing down from my internal customer" situation.
I was speaking from my own experiences. At my first real programming job I was lucky enough to work with a handful of obscenely talented programmers and they very commonly would implement incredibly stupid or lazy solutions because they were easier to get through code review.
Ah, I see and empathize. I've had some very long code reviews on account of writing code above my reviewers' skill levels.