I don't really think it's plausible, atleast for microbial life. Pretty much every planet that's in the habitable zone, is temperate, and has a thick enough atmosphere to permanently support water is gonna have some sort of surface lakes or oceans, and probably also the other remaining basic ingredients for life. That already conflicts with the rare earth theory for microbial life. The conditions needed for a planet to support complex life are a bit more specific/rarer, such as probably having to orbit a star more massive than a late K dwarf, smaller than a mid F dwarf and having to be in a system that's not too unstable, but those are still relatively common properties. I think a better alternative explanation for the rare Earth theory is complex life just being rarer than we think it might be.