Yes, the theater that the reviewer saw it at does matter if the projection quality was bad. If he says, "the 3D was good/bad" and just leaves it there, that doesn't really tell you anything about the nature of the 3D, the quality of his theater, his taste in 3D, or why he had a good/bad experience. Those kind of comments don't help anyone.
Projection quality is literally different across the board at every single theater with every single projector. You can't depend on reviewers to make the best viewing decision for you. You just have try out different 3D movies at different theaters and see which one has consistent projection and a good price to satisfy your needs. If all dimly lit scenes look more like 2D than 3D, try a different theater the next time you go see 3D.
Personally, I always have a better experience at my local digital IMAX. The screen is bigger, the sound is better, the calibration is perfect, the chairs are tall, they always get the exclusive aspect ratios, and the theater is empty during Mon.-Thur. $10 matinees. You just have to decide if the extra ticket price is worth the improvements you get over your local theaters.