That must be what they mean. Obviously a cell would have a boundary, and it might be called a wall no matter what the composition might be. Sagan's Origin of Life buddies were always trying to find a chemical process that would create that first cell boundary of the first cell.
That must be what they mean.Or they could just be wrong. They equate "no cell wall" with "primitive", when in fact the opposite is true. All cells have cell membranes, but cell walls are present in bacteria (prokaryotes), fungi, and plants, and not in animals.