If you're visually impaired, you can hit it even with just a few icons on a 14" laptop. Fonts anything other than tiny + overloaded menus + even a handful of app icons means I always hit this unless I'm docked.

Hacky menu bar modification tools are basically an accessibility requirement for me, and my vision isn't even that bad. (Best corrected is 20/30 or 20/40 or so.) People with serious impairments are totally screwed by this on macOS, sometimes even with large external monitors.