My understanding, which is to be taken with a grain of salt, is that there's an additional constraint, not stated in the Scientific American article, that the plane curve be irreducible. The example of x^4 is reducible, it's x^2 * x^2 among other thing. The actual conjecture is expressed in terms of genus, but this follows from the genus-degree formula.
The reason for the confusion is that a smooth, projective plane curve of degree d has genus (d-1)(d-2)/2, which is 2 or greater starting at d=4. Hence the phrasing in the article, which is missing the “smooth, projective” hypothesis. The equation y = x^4 doesn’t define a smooth curve when extended to the projective plane, because it has a singularity at infinity.