The function calls ``sqlite3_open()`` that, if I understand its documentation correctly[#], returns a new connection object in all cases (that is, even on errors) with the only exception of "out of memory" (in which case it sets the second parameter to ``NULL``).

I think that the new connection object should be immediately released in case of errors, passing it to ``sqlite3_close()``.

.. [#] http://sqlite.org/c3ref/open.html