Earlier quoted context omitted.
An error related to the file system, for example.
A file system error isn't an error happening in the compiler . The file system is an external system. So this error isn't really any different than a syntax error or type error. I would not treat it differently except making a different error message. Of course you cannot parse a file you cannot read, so there is a dependency which means that sooner or later you need to "act" on the error.
Could you share another example where accumulating errors makes sense?