That would be an interesting research topic! Perhaps the average color of the un-calibrated displays is not the same as the one of a calibrated display.

For example most TV are put in some very colorful mode from factory and most user don't bother to switch it. The same is true for old Samsung mobile phones which had a lot of popping colors. You could switch them to more realistic tones but nobody ever did this.

But you can still have other problems depending on the dynamic range of your photos.

I often edit my photos so that stuff in shadows are not perceptible. The problem is that I edit on my laptop LCD screen, but on my phone OLED at default settings, I see clearly everything that was supposed to be hidden in the shadows.