Making a mono-colored or heavily-color-themed background is a common thing in art. It is not universally achieved by the lazy method of using a flat tone or wash/gradient as a background. Either this set of implications is incredibly obtuse, or the meaning of plain_background is somehow supposed to be loose enough to include simple_background and detailed_background within itself.
[EDIT]
... Sorry, wrong category at first. I've only posted in the forums like twice since categories were implemented (and I think they still do nothing?), so I forgot they existed.
Updated by DrHorse