I've got a Galaxy S2 that proves that statement wrong. Still use it for testing kernels.
Screen is still just as good as it was when I bought it.
I have an S4 in my bag as a backup phone that was used daily for over two years by my daughter, screen is still as good as the day it was bought.
The only way to burn in ANY display is to stick it on a static image at full brightness for months at a time.
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That's a display phone. You can still see the demo burned in on the screen.
This iPhone shows the same issue. It was left on a static image too long.