Nintendo 2DS

[Kitsu]

I mean, it'll probably be okay, but my siblings go through DS's every year because their bottom screens get so gouged out that they're unusuable (at one point my sister decided a fork was a suitable replacement stylus...)

These sorts of things wouldn't really be influenced by whether the screen is protected by a clamshell or not; the only thing that would help prevent these would be teaching kids to be more careful with their electronics.
Though one of those plastic screen protector sheet things they have for iPads might probably be more helpful.