I am calling BS on this new theory - agree or disagree??? 

According to an article in the "New York Times", the new rule of cell phone etiquette in this day and age is . . . only leave a voicemail if it's a LIFE-OR-DEATH EMERGENCY.

Otherwise, hang up and send a text summarizing what you were going to say.

The theory here is that leaving a voicemail is a BURDEN on the other person.  They have to actually go to the trouble of pressing the button and listening to it.  And there's nothing you'd say in a voicemail you can't say in a text.