In my mind, a lightning withdrawal that pays sufficient fees can only be censored if a sufficiently large group of "anti-withdrawal" miners collude to reject it. If the anti-withdrawal miners have less than 99.9% hashrate, then, given that, per the LN protocol, there are 2016 blocks to mine the withdrawal tx, there is a good chance the remaining miners (0.1% or more) will mine it. And at that point, miners have to perform a 51% attack to "undo" it.
But I suppose, if you define "merely refusing to mine it" as different from a 51% attack, my definition does allow an edge case where, if 99.999% of hashrate consists of anti-withdrawal miners, then even if they won't perform a 51% attack, you're still unlikely to get your withdrawal transaction mined, because too few miners are "on your side" -- the ones who are, are unlikely to find a block in LN's 2016 justice window.
But even in that edge case, I think my definition still works: I carefully chose the phrase "render...invalid" so that it would call to mind transaction validity. Your transaction would not be invalid just because 99.999% of miners refuse to mine it. If the withdrawal transaction(s) remain valid, the service still counts as a layer two, even if most miners refuse to mine it.
One might wonder if that also means my definition can be shortened by removing the reference to a 51% attack, since, by most definitions, a transaction is not rendered invalid just because miners attack it with a 51% attack. But I think the reference is still useful, because in the case of lightning, the justice tx competes with the finalization tx to spend the same input, and so, if a 51% attack causes the finalization tx to get sufficient confirmations before the justice tx can get them, then the justice tx is actually rendered invalid -- because it tries to spend an input that has already been spent.