Sort of true. Since the Mac allocates a fixed block of memory for every app, quitting apps out of order can leave blocks of free memory that are a fixed size trapped between other app's memory spaces. It's likened to a fragmented hard drive.
If an app launches that needs a memory allocation small enough to fit into one of these holes, it is possible for it to squeeze in. It doesn't always happen though because the system looks for the largest block of free memory which for most people is at the end of the stack, not the middle.
Quitting all the apps, even out of order, typically will let the system see whole stack as available again. However, the system heap usually grows with every app launched, so the system may still reserve some memory and not give it all back.
All of this, of course, refers to the Mac prior to OS X. OS X is so different from the previous system architecture that calling it a Mac is pure marketing. Similar to how Win3.1 and Win2K share the Windows name.