You can’t generalize the term “modern amp” to be able to drive a certain power and impedance. You have to look at the specs, topology, what is the output stage used (MOSFET or BJT) what are the oltage rails.
There are many “modern amps” that won’t put out 1W into 32ohms. That’s a lot of power that most headphones simply have no need for. Is it Class AB, Class A, push pull Class A or single ended Class A, etc? Some single ended Class A headphone amps won’t put out more than 100mW into 32ohms. Most opamps won’t put out more than +/-18v. There are special ones that do +/-50v but lower current. Higher power amps tend to be discrete output for this reason - you can’t get opamps that make more 36Vpp swing.
To estimate max output power, we can always use Ohm’s law and stated rail voltages to estimate the max power assuming there is no current limit. For example, the Magni Heresy PSU is +/-17v or 34vpp. Divide that by 2.83 to get the max RMS voltage of 12.0Vrms. According to Ohm’s law, power is equal to voltage squared / resistance or impedance. So power = 12Vrms ^ 2 / 32ohms = 4.5w max. So that’s the case with unlimited current and the max you can hope to get.
The current limit is imposed by either the PSU or the output stage. Looking at the OPA1688 we see it is capable of +/-75mA. Since there are 4 dual opamps that is 4x 150mA peakor 600mA max current. We divide by 2.83 for 0.21Arms. Power in terms of current and impedance is current ^2 x R. We now get 1.4wrms in the current limit.
Of the two values 4.5Wrms and 1.4wrms, the latter is the limiting factor.
Finally, we need to look at wall power supply. Can it provide 1.4Wrms? I don’t have one in front of me but I recall it was a pretty substantial one capable of more than that. Keep in mind that these are the absolute rail to rail assumptions and actual output may be a bit less.
I hope that was helpful and one can use this approach to calculate Class AB type amp max power. For Class A push pull that transitions to Class B it is also valid. but cannot use this for SE Class A amps.
Cheers,
XRK