I don't think so. The Flipper Zero isn't an SDR.

What's the earliest reference to this attack you can actually provide?

I’m talking about the earliest cases. The earliest references depend on the particular standard of crypto. KeeLoq is a very famous rolling code standard where attacks go back to 2007 and earlier.

RollJam is known since 2014 [1]. It was popularized later through a custom device [2].

[1]: https://spencerwhyte.blogspot.com/2014/03/delay-attack-jam-i...

[2]: https://www.wired.com/2015/08/hackers-tiny-device-unlocks-ca...