I found a 2000 Jeep on Craigslist a couple of days ago. It was cheaper than any new-ish Jeep that I've seen ($4k). He said that it had some rust on the frame that would need to be addressed in about a year or so. I asked for photos.
Yikes...
I've never seen a TJ that was this rusty. There must have been some salt water immersion involved.