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The only times I have seen the starter not be able to turn a rotary over is when it had either seized the bearings onto the E-shaft do to lack of oil (on a running car) or when a small bolt had been dropped into a motor during a rebuild and had jammed in the stationary gear.
Not saying those are the only options, but the starter has enough power to chug the car along when it's in gear, so if it can't turn the motor over there is something seriously wrong.
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