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I am pretty certain that Marketo, like all email programs, is only able to track an open if images are displayed.
So if you send it to 100 people, and 20 people actually open it, but only 10 have images turned on, your open rate would show as 10%.
Yep, Ari is correct. Just to clarify your initial question Andrea:
Is the open rate based on someone clicking "display images" in the email?
I am thinking that if they dont do that then Marketo doesnt know they opened it.
Correct! And in most email clients, images are disabled by default, so you shouldn't put too much emphasis on open rates for this reason. Click and open-to-click vs your industry/historic average are generally much better indicators.
Thank you Ari & Adam for the helpful information!