That's a pretty old article (although everything on juicystudio.com is well worth reading) and the major screen readers have moved on a bit since then. The article also mentions that this issue only occurred when using
display:none; with links (anchor elements) - not form inputs. JAWS especially uses a completely different mode to interact with forms compared to plain text & links.
With regard to Fangs, I'd be really careful about extrapolating anything concrete when using this add-on. It is just a developer tool - not a screen reader in its own right - so there may be some things that it does not emulate correctly.
I'd agree that adding a descriptive label would be a good idea to cover any edge cases but only if that label too was hidden using
display:none; - otherwise the output could be a bit confusing for sighted screen reader users (and, yes, not all screen reader users have sight problems).