Steps to reproduce:
# Make a new scene
# Add a cube primitive
# Remove its material
# Make it static
# Bake

Result:

{{OpenCL Error. Falling back to CPU lightmapper. Error callback from context: IntersectionApi::Commit failure: likely out of GPU resources.}}

{{Light baking failed with error code 3 ('BakeJobInitializeLightmapData' failed because it ran out of memory.).}}

Note:

This reproduces when there are static objects in the scene but none of them have valid materials. If there is at least one valid object in the scene, the bake will complete successfully.