Well, we haven't seen the Configs of the next generation of MBP yet, have we!
It would be constrained by physical dimensions and the amount of RAM you could put on a DIMM, and also how many slots there were able to be put into a laptop. Price would also come into the equation. With 6GB a DIMM being made now, you could be looking at 12GB presumably. The OS could take more. The chipset it seems would also limit the higher amount, however, it's likely to change in the upcoming 10 months. They'd be on Nehalem by then presumably and be looking at a potential route to Calpella.