The 3-in-1 has two different types of memory that it can use for running games: PSRAM (not to be confused with SRAM, which holds save data) and NOR flash memory.
It only takes seconds to load a game into PSRAM, but the data is gone when the power is turned off, so you have to load the game each time you want to play it. It takes a few minutes to load a big game into NOR, but once it's there it stays there even when the power is turned off or the cart is removed.
When the 3-in-1 was first released it could only run games from NOR (the PSRAM was for running the DS web browser, which requires a RAM cart), and you can only have one game in NOR at a a time. This is where the "only holds one game at a time" thing came from.
Once homebrew authors figured out how to run games from PSRAM that limitation became irrelevant. You can have as many games as your slot 1 cart can hold.