It's a solid lifter unlike a hydraulic like found in most cars so stuck would have to be rusted in the block bore.
 
Unusual for a lifter to stick in the block bore unless the engine has been sitting a long time with water in the crankcase.

Usually other things will be stuck sooner, like the piston rings stuck on the bore, entire engine stuck.

Could he have possibly said stuck valve? That is very common, again usually caused by sitting with water getting in the engine, usually down the exhaust. They can usually be freed up with penetrating oil and tapping with a small hammer, prying closed, repeat, repeat.

If it is a lifter, and it is stuck with rust, it could probably be freed up by soaking , tapping it down, turning the engine through to bring it back up, tapping it down. Just be sure the cam lobe is down before driving it down.
 

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