In-display fingerprint sensors have become commonplace in virtually all Android smartphones, for better or for worse, and five years later…
All of the phones I have had have had practically flat fingerprint sensors, For example, the Pixel 3a XL which is closest to me right now has an inwards facing sensor.
I believe OP was referring to the fact you’d need to pick up the phone to access the rear sensor, not about if the phone sits flat.
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