Not true.

A wheel is the sum of it's parts and the quality of the build... some rims are so strong that a lower spoke count can be used and you will have a wheel that is just as strong or stronger than a more highly spoked wheel with a lesser rim.

I build mtb wheels for some big dudes... we're talking about 240 pound guys doing 6 and ten foot drops.

32 spoke rear wheels serve them just fine when the parts are properly selected.

Same thing applies to road and touring wheels... a stronger rim can use less spokes which can also be straight gauge and not cause any issues.

I'm a lightweight but I build my own wheels so that a 240 pound person could borrow my bike if they had to and I would not worry about those wheels a single bit... some have 32 spokes and some have 36 and a few have 40.