Interesting read, but as usual, blown out of proportion. This would happen with an iPhone too, if that's where this article wants to go.
Unless your device has been encrypted, all data stored on it is still there after a device wipe, it's just not easily accessible. Think about a book page you cover with a sheet of paper; the text is still there, you just can't see it. If you really want to delete the text, you would have to print something else on top of it. Same thing with data. After a wipe, the only way to get rid of it is to write something else on top of it.
It's the same on a computer hard drive. And yes, even encrypted data can be recovered, with the difference being that said data is harder to translate into usable information than 'regular' data.
Also note that they did use data forensics tools, even if 'easily' available ones. It's not something your average petty thief will have on hand.