Predictably, I disagree with this statement as a blanket fact.
In particular, anyone I ever played football games with on Gen-6 consoles (PS2/XBOX) preferred Madden to other football games from an animation perspective because it was perceived as more fluid and less jerky, notably when the ballcarrier was running. The technology before that point wasn't good enough for any game to have "good" animation or for there to be any useful comparison, IMO.