This might not be a complete answer, but it's coming from experience and might provide some pointers. Memory leak in NodeJS is one of the most challenging bugs that most developers could ever face.
But before we talk about memory leak, to answer your question - unless you explicitly configure --max-old-space-size, there are default memory limits that would take over. Since certain phases of Garbage collection in node are expensive (and sometimes blocking) steps, depending upon how much memory is available to it, it would delay (e.g. mark-sweep collection) some of the expensive GC cycles. I have seen that in a Machine with 16 GB of memory it would easily let the memory go as high as 800 MB before significant Garbage Collections would happen. But I am sure that doesn't make ~800 MB any special limit. It would really depend on how much available memory it has and what kind of application are you running. E.g. it is totally possible that if you have some complex computations, caches (e.g. big DB Connection Pools) or buggy logging libraries - they would themselves always take high memory.
If you are monitoring your NodeJs's memory footprint - sometime after the the server starts-up, everything starts to warm up (express loads all the modules and create some startup objects, caches warm up and all of your high memory consuming modules became active), it might appear as if there is a memory leak because the memory would keep climbing, sometimes as high as ~1 gb. Then you would see that it stabilizes (this limit used to be lesser in <v8 versions).
But sometimes there are actual memory leaks (which might be hard to spot if there is no specific pattern to it).
In your case, 256 MB seems to be meeting just the minimum RAM requirements for nodejs and might not really be enough. Before you start getting anxious of memory leak, you might want to pump it up to 1.5 GB and then monitor everything.
Some good resources on NodeJS's memory model and memory leak.
Some debugging tools to help spot the memory leaks
