Nope, not true! lol, I've learned that it's possible, I just have to not be to picky and "perfectionist" on it. I usually have a bit more frizz/flyaways on 2+ day hair, but it's totally possible. You just have to find the right routine and products that give you awesome 1st day hair with GREAT hold, that doesn't weigh you down. If the hold's not there, the curls won't survive the night. if it's too heavy, the roots go flat and look gross.
CG/Mod CG (soap bars) since 8/12/08
CO wash/Cond: Kathymack & Flowermoon Castille soap bars, V05 Chamomile Tea, Suave Ocean Breeze, Biolage Conditioning Balm
Styling loves: DIFFUSING! CK, KCNT, KCCC, FOTE (on dry hair only), Re:coil, Proclaim gel
Not sure about: Boots, Tweek, KBB Milk, DMHJ
HATE: plopping, FOTE on wet hair, BRHG