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Well also the internals and the battery itself is more loose so it's less resistant to high G-forces
I'm assuming you must be referring to modern phones here right? I never needed a case on my phone until we started getting into S8 territory when phones became incredibly flimsy and fragile. My Note 4 was plastic and aluminum and survived tons of drops. Same with the LG V20 I replaced it with. New phones are required to have a bulky case added on, which defeats the purpose of making them thin and using glass construction. Also modern phones are way thicker than the older phones with replaceable batteries even without a case on them.