there is just way too many phones on eBay with activation lock on, i would never tell a first time buyer to a used one from eBay. i do not understand why eBay is allowed to list stolen phones. as far as i am concerned if that seller does not know how to turn off activation lock, that phone is stolen and for some reason , eBay is allowed to get away with it
in my recent shopping experience i had to pay at least $180 to get an iPhone that does not have activation lock
i think your best bet is YES buy an unlocked phone !! but buy one from swappa.com, they check the Serial Numbers / IMEI / MEID, that way you know the phones are good to go
once you pay for the phone you are given the IMEI / MEID of that phone, and you can check it to make sure its not locked with iCloud
http://lcoud.com/activationlock/
swappa guarantees that the phone is not blacklisted.
they don't guarantee it will take another company's sim card though
thats between you and the seller
http://swappa.com/risks
i came across a few eBay sellers that still list there phones as "AT&T" even though they are not locked
when in doubt. buy a VERIZON iPhone 5 or higher
don't buy a verizon 4s. i made that mistake recently i cancelled the transaction 1 minute later and the seller was cool with it