Owning both for some years I can say my CZ 452 Special
has show itself to be capable of a far higher level of precision shooting when compared to my Marlin 39. Shooting examples of each owned by others pretty much mirrors my results.
My 452 Special @ 50 yards:
And at 100 yards:
And the Special was only $189 when I bought it back in 2002. Actually the only 22lr rifle I owned that was more accurate with some brands of ammo was a $675 Sako. If I ever get around to improving the CZ trigger things will only get better.
As to the references of CZ being junk that is simply a crock of horse manure. Apparently there are those who have their favorites and when something different is mentioned they will badmouth it in an effort to elevate their favorite. I picked up a CZ 452 American a few weeks ago and and if it can be classified as junk then I would rank my 39 in the same class as well.
I enjoy owning both. For fast standup shooting/plinking the 39 is the rifle I choose , for shooting groups I grab the CZ.