In any case, I've dropped my 3GS phone about a half dozen times, twice from 3 feet. No damage so far; maybe some scratches, but I use a matte screen protector (more easily scratched than the glass) and a custom vinyl backing (edges and corners still exposed). There's some dust now behind the screen from the impacts, but a case might not have prevented that anyways.
If I had to put the 3GS in a case, I probably wouldn't have bought it in the first place. But then I prize thinness in phones over other things, since I put the phone in my pocket.
At least the iPhone 4 bumpers are less intrusive and ugly than most 3GS cases. Still a shame to cover the stainless steel edge when they finally brought stainless steel back in the iPhone design.