The thing is, there are a lot of small systems maintained by a lot of small teams. Unfortunately, when Joel wrote

“They did it by making the single worst strategic mistake that any software company can make: They decided to rewrite the code from scratch.”

some people took the “any software company” to heart and now apply the same principle even in those smaller contexts when sometimes the code really is that bad and rewriting the whole thing really is by far the best plan. I’ve seen very senior people citing the Netscape case study to support a no-rewrite position while discussing a 10kLOC system that could be rewritten from scratch in a couple of weeks by a single developer.