I remember seeing a study that showed that people who take notes on paper do better vs people who take notes on a laptop. People who didn't take notes(or take very few) weren't mentioned.
You're correct that most new studies compare handwritten vs. laptop notes. The effect of handwritten notes vs. no notes was studied quite a bit earlier, and I believe this effect is now as uncontroversial as psychology can be.
A good review of the literature (from 1989) is found here:
I remember seeing a study that showed that people who take notes on paper do better vs people who take notes on a laptop. People who didn't take notes(or take very few) weren't mentioned.