Yes, but if the user wishes to avoid their own security like this, they can already do it a thousand other ways (and to no adverse affect, there is no opportunity for an attacker to exploit this, I don't know what you're getting at).
Atwood's point is that checking the "referer" will both be unreliable and, more importantly, lead to false positives; there are better alternatives, namely, double submitting cookies as I have pointed out elsewhere with regard to this article.