First of all, it's not true that a jammer can't simulate silence. It's tricky and requires phase locking with accurate propagation delay estimates to the receiver, but possible.
It also does nothing against a relay attack where the client can't hear the server directly. For example, I could relay the wireless AP from two rooms over so you'd connect to that one entirely through my relay.
http://www.usenix.org/events/sec11/tech/tech.html#Gollakota
The abstract says they've made it work on busy networks.