Error: 'out of gas' in simulation result

When I sign and then simulate a transaction bundle, sometimes it will return the expected result with a gas used amount, while other times I would get a simulation error and it would have in the firstRevert field: error: ‘out of gas’. The gasUsed would be higher than the gasUsed in the result without error and if I were to run the simulation, its about 50/50 that it works and tells me it used lower gas or it fails and tells me I am out of gas and the gasUsed in the simulation is higher. The issue though is that I have no clue why it tells me I am out of gas since I am not even filling out type 2 fields.