Not just easy, but TOO easy. You're right--it doesn't HAVE to be removed. But I think it should be.
It's scrambles like those that make the single records/rankings meaningless. I would not mind filtering if rankings were not kept for certain categories (2x2 single & pyraminx single, for example).
By throwing out scrambles less than 4 moves on 2x2, we're only eliminating 384 scrambles out of ~3.7 million. I don't think as a community we lose anything my disallowing those scrambles. The odds of those scrambles occurring anyway are very low, but I don't like the idea of them coming up at all. Where would you draw the line? If the scramble was only 1 move, would that be okay? What about a pyraminx solve in which only the tips are scrambled. What about a scramble that brings the cube back to the solved state?