I don't really see how people get to much more than $40K a year in expenses. That's like a $2K/month apartment and a pretty nice used car with lots of margin for going out.
Granted if you're too aggressive with IRA investing or student loan payoff you can get in a situation like this. That's my downfall - I'd rather be in the market, but you really shouldn't expose your emergency fund to that kind of risk, especially given near-perfect correlation between market performance and personal financial security.