By most people's definition of the term, sure. It ends up being a loss of memory within an object or set of objects that no longer have any practical use to the application and the irreclaimable memory can grow over time.
> Maybe a reference cycle is hard/impossible to GC
This is basically the issue.
It is relatively common (particularly among younger programmers who haven't been bitten by this already) to have a situation where you have an Android Activity that creates and holds a reference to an event listener which traps a reference to the activity itself. If the Activity doesn't clean up the the listener reference in its onDestroy (which is an Android lifecycle callback, not related to the Java GC) and neither reference is a WeakReference you wind up with a listener object which references the activity and an activity which references the listener object, neither of which is suitable for naive garbage collection... so now you have this lingering Activity object that is probably no longer associated with the application's window but lives on. If the app is designed such that the user keeps pathing through this Activity and the activity consumes lots of memory, it isn't hard to get fatal OOMs from this situation.