Well, with ZFS you want to avoid hardware RAID controllers completely. The protections from ZFS only work if the filesystem doesn't have anything in between it and the actual disks. Depending on your vendor, it can actually be difficult to get a card that lets you have JBOD access to a large disk array.
The only exception that I can think of is encryption. You could wrap a disk with an encryption layer in software, but then you could still to make a separate virtual device for each disk.
A hardware RAID controller could limit ZFS' ability to provide integrity, but not enough that I would say another filesystem does a better job there. All filesystems are compromised by the failures that traditional RAID can introduce.
That said, I would never recommend a hardware RAID controller for use on any system. They add additional cost and additional failure modes, but give little in terms of benefits.
The only exception that I can think of is encryption. You could wrap a disk with an encryption layer in software, but then you could still to make a separate virtual device for each disk.