Not true. The bolt of a Marlin 39 just slides out the back, allowing cleaning from the breech just like a bolt gun. It's also a takedown, so the whole action just comes off the barrel and is not in your way when you're cleaning the gun.
One other consideration is the frequency that a .22 needs to be cleaned. I clean mine once a year, but I wipe the external surfaces with an oily cloth after each use.
Some members of my bench rest club only clean a .22 when accuracy falls off. Many of them say that can be 10,000 rounds or more. They say that too clean of a barrel ruins their accuracy.