Subject to devices in use, firmware they are running etc. My Nexus One, Galaxy S with TouchWiz UI, or the Nexus S do not have jerky scrolling for instance. The G1 does. http://www.youtube.com/watch?v=9xEKrY0VQKQ
So it is possible today for people to buy Android devices and not notice any out of the ordinary jerkiness.
Sounds like what people said about buying American cars in the mid 80's. It was quite possible to buy a great, reliable American car. Unfortunately, other cars in the group pulled down the perception of those cars as a group, in sharp contrast to perceptions of Japanese car makes.
The whole point of the article is that the subjective matters -- literally to the tune of Billions.