Verizon is selling 1.5 and 1.6 devices right now - that's how they're segmenting their product line. AT&T and Apple haven't sold an iPhone 2G in years.
While individual phones may ship with the old version all the Verizon Android phones I'm aware of have the ability to be updated to 2.1 in a carrier supported way.
I'm genuinely surprised, though, that the Eris has been updated.