Bind variables in PHP-MySQL
The static variable 'ACTIVE' can not be messed with from the outside in any way, is therefore safe in the first example. 

The only reason I can come up with to still warrant a change to the second snippet is for consistency and future refactors. Suppose you want to change the method where this query appears and you want to give the user the freedom to choose between ACTIVE and ARCHIVED? To prevent yourself from making a very quick change and potentially creating a vulnerability, you should possibly make a habit of escaping every variable. 

(Though in the specific case of a status fields where only a specific list of constants is valid I'd definitely also validate that the input is a valid input.)