Like Apple says, the dataFromPropertyList:format:errorDescription: method does not follow the object ownership policy. The method reference describes it. I have tried to search for "need to be released by the caller", but no useful results.
Here's a quote from the reference:
Special Considerations Unlike the normal memory management rules for Cocoa, strings returned in errorString need to be released by the caller.
I am almost pretty sure that this one is not the only case where this exception to the policy occurs.