I've done a few no boil extract IPAs where I've just heated the wort to whirlpool temps. The results were just fine - as good as any other extract IPA using a normal boil that I've brewed.
I have a Berliner Weisse that is almost ready that uses an even simpler method. I fill my fermentation keg with hot tap water, add wheat DME, pitch lacto, and let the sour fermentation go. I did a short 15 minute boil to kill the bugs and add a small amount of IBUs, then chilled and pitched Sacc.
I don't think that this would work for every style, but it does have a place for some brewers and styles. I might try an extract and dry hop IPA with no heat at all sometime soon just for the heck of it.