Strong disagree about laziness. If the dev is lazy they will not make a path for it. When they are not lazy they actually make a path and write a comment explaining why they think this is unreachable. Taking the time to write a comment is not a sign of laziness. It’s the complete opposite. You can debate whether the comment is detailed enough to convey why the dev thinks it’s unreachable, but it’s infinitely better than no comment and leaving the unreachability in their head.
Laziness might or might not be involved in either path.
A stupid developer might not even contemplate that something could happen.
A smarter developer might contemplate that possibility, but discount it, by adding the path and comment.
Why is it discounted? Probably just priorities, more pressing things to do.