The term has shifted over time, then; the point with the epithet thrown toward certain kinds of GMs was that they either completely didn't care about what their players get out of the game, or actively felt like players dying was a virtue. Micah is not in either of those from things he's said; he does feel that the integrity of the setting (in a simulationist fashion) is important and will sometimes lead to PCs dying, but nothing suggests he considers that a virtue when it happens. Its just the price of doing business sometimes.
A usual giveaway is whether people make effort to ensure that its possible to avoid getting chewed up if they play intelligently and carefully (and not setting a stupid high bar to that); the real old-school viking-hats didn't care.
