This bug either wasn't fixed or there has been a recent regression.

Ubuntu lucid
openssh-server 1:5.3p1-3ubuntu1

/etc/default/ssh: SSHD_OOM_ADJUST=-17

As well as causing kernel panics, a malicious user can use this
technique to kill off trusted root daemons and (if they use a port >=
1024) launch spoofing processes.

Not only is this a DoS risk, it can also lead to takedown of critical
system components required for the SSH session to work (NetworkManager
etc.)


** Changed in: openssh (Ubuntu)
       Status: Fix Released => Confirmed

-- 
hardy: openssh-server oom_adj can lead to denial of service
https://bugs.launchpad.net/bugs/293000
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