i think the issue and risk about recliners is about using normal bed or throw pillows, often many of them, to prop mother and baby(ies) up. i have sat awake on my recliner with my EZ2nurse pillow crammed in between the arms, i actually moved it in front of my computer in the early days so they could sleep like that while i learned how to be a twin mommy online. and yah i will say that how i happen to have it did feel relatively safe, but i also had a firm flat totally square nursing pillow in a totally firm square (ikea square!) armchair. nobody was going anywhere, heck i couldn't even move if i needed too. and of course i was awake, i was totally upright.
but what im saying is that yes i can see that would a full twin nursing pillow and everything fitting just right, that i can see how a reasonable safe set up could happen.