A doctype enforces a certain set of standards for the browser. If a page does not include a doctype, browsers will usually use some kind of quirks or transitional mode, which is more lenient about markup mistakes (but is bad practice and may display items incorrectly).
Essentially, strictly speaking, you can't set that element to height 100% using that browser's set of standards. It'll try to predict what you wanted to do if you don't include a doctype or include a transitional one and adjust the page's styling accordingly.