Why so harsh Steve? It's a "Stairways" article. All writers must consider their target audience. I thought the article was a great primer on bookmarks, indexes and heaps. The three guidelines laid out regarding choosing a clustering key are critical to remember. Even veterans can use some re-enforcement of the fundamentals from time to time. I thought the article was great!
+1 to that. It is a very good article and as the stairway progresses will for sure leave the audience with a sound understanding of the working of the indexes.
We have used the non clustered indexes on a heap approach for tables that are not joined with other tables and where range queries are infrequently made.
Transaction tables forming part of entity-relationships though, as a general rule of thumb, are clustered.