I think the more common case is listings that are technically "open" but due to slow internal processes, repositioning, etc etc, no work is being done towards filling them that is visible to candidates.

For example, I've personally witnessed situations where the funding for a role gets postponed to next quarter, but my manager just kept it open anyway, either out of fear of missing out on the perfect candidate if they stopped accepting apps, or because it's simply easier than going through the HR process to re-post it in a month.