no, because the notes are external content not generated by the relays, the relays cannot be trusted ever, the client needs to verify everything. you're advocating for clients to "just trust me bro" which is completely wrong. the practice of displaying a single integer count is the problem, and clients downloading tons of events just for that are the problem. anyway, there's a COUNT nip since a long time ago that I helped shape precisely to unburden relays from this bad practice.
And you’re trusting the relays to give you the right count…
I'm not because I don't use the feature. but if you're going to ask for everything just for a count, might as well trust the relay for that, because it's meaningless anyway and the relay doesn't have to send everything and you don't have to download everything just to discard it afterwards. but just because I don't use it doesn't mean that other don't as well, so if clients will do it because they can, they will, and in that scenario, it is best to have a better solution with tradeoffs both agree.