The occasional viral instance of poor enforcement would do the trick.
I don't actually think there's a majority in the "COCs are evil" camp - not even close, but there's a very vocal minority group that has a lot of energy and is always ready to pile into a thread that is in any way tangentially related to COCs and post comments like "Moderators are evil right guys? Remember that time it was badly enforced? That means COCs are bad!" And they get upvoted for that. It's kind of amazing.
Argue about the rules in COCs, or about the way they're enforced. Commenting things like "the evil mediocrities that enforce COCs" is just cringe-level bad.
I don't actually think there's a majority in the "COCs are evil" camp - not even close, but there's a very vocal minority group that has a lot of energy and is always ready to pile into a thread that is in any way tangentially related to COCs and post comments like "Moderators are evil right guys? Remember that time it was badly enforced? That means COCs are bad!" And they get upvoted for that. It's kind of amazing.
Argue about the rules in COCs, or about the way they're enforced. Commenting things like "the evil mediocrities that enforce COCs" is just cringe-level bad.