I actually changed my mind a little after posting that comment. I think it was mentioned elsewhere also, but even something that I would consider "bricked" could still probably be recovered by someone with access to the right tools (ability to reflash via JTAG, replacing chips etc.)

I would refine my definition to be that a "bricked" device is something that has occurred via a failed software update making the device inoperable to all but the tiniest subset of users.