As I understand it, it depends on how much they want to spend to forensically examine the drive. The standard is multiple writes or physical destruction of the drive - with the latter being the norm for more modern flash storage.
So, logic dictates that yes it must still be recoverable or they wouldn't have the standard set to multiple wipe with random data being written to the drive. Visit/find a thread on Slashdot with regards to securely wiping drives and read the comments. There's still some smart people there who can describe it much better than I can, as well as explain the methods used in forensic examination or in data recovery shops.
For example, I recall that you could read after a zeroing out by using an electron microscope to check the position of the bit on the physical platters in ye olden spinning rust disk drives. Among the questions you'd probably ask yourself is 'Who am I hiding it from?' If you're really concerned, destroy the drive.