Speaking from a fair amount of experience, someone noisy is a lot harder to live with.
Messy, you can step around, you can ask to pick up politely. Most people realize that they're messy.
Noisy, there's no escaping it, especially when you're trying to sleep. Lots of people don't realize when they're being loud, which is why they are loud. And there's only so far you can go before you get to the point you want to scream "shut your big fat mouth" or "turn the damn music off".