A factory state is what makes an explicit fixture short

A test that creates its own data is only maintainable if creating it is one line, and a state is what makes it one line.

public function gold(): static
{
    return $this->state(fn () => ['tier' => 'gold', 'credit_limit_cents' => 500_000]);
}

public function withOverdueOrders(int $count = 3): static
{
    return $this->has(
        Order::factory()->count($count)->overdue(), 'orders'
    );
}

// Customer::factory()->gold()->withOverdueOrders()->create();

Without states the explicit fixture is six lines of attribute assignment and people start querying for existing data instead, which reintroduces the ordering dependency. The states also document the domain: a list of factory methods is a readable summary of which states a model is expected to be in.