Lmao, I was making this point at work yesterday. It's really difficult to justify using a modal if you care about accessibility. It's not that it's impossible to do correctly, but even when it's done "correctly" it can still be confusing for users navigating with keyboards / screen readers. So modals are almost always either too much effort to do right, or just not the best approach.
Another thing I'd add to this list is that there are some people who browse without JS enabled. I know it's unpopular to care about those folks these days, but it is another reason to avoid modals where possible.