I think so, actually. The reason is that usually carbon-based life gets its carbon from CO2. But life doesn't stop growing because it's going to kill itself, cf. global warming. So photosynthesis on these planets might continue until their atmosphere is drained of CO2 and they freeze. Then again, I suppose there could be an equilibrium, but that equilibrium would require the planet to remain "uncomfortably" cold to suppress photosynthesis.

Of course, that's a completely different argument from the one the researchers had.