I think he means in OpenGL, if memory is allocated (as in a C struct or array), it isn’t released, or is it? memory leaks are usually found in C/C++ because you have to deallocate memory even if there is no longer a reference to it. Probably more of a concern of LWJGL or JOGL than the scene graph API.
Java handles this well with the garbage collector, but it is possible to have objects persist without a desire for them to persist…meaning it doesn’t get garbage collected if there is a reference to the object.
Example:
public class mainLoop
{
Scene scene1;
Scene scene2;
…
scene1.start();
// if you are done with scene1, set it to null or else the
// object will linger without being garbage collected.
scene1 = null;
scene2.start();
…
}