You could make a case on who to start between him and Fletcher but i'd rather play Fletcher.
In Bayern Munich there's simply NO way he would start, who's place is he gonna take? Van Bommel? i don't think so. Schweinsteiger?
Milan don't really need him and i wouldn't bench Pirlo for him, he's not a dm so he won't take gattuso/ambrosini's place that only leaves him battling with boateng, flamini and probably seedorf for the other place and even then i wouldn't consider him a definite starter.
Where would he play in Arsenal? Not Song's place, obviously not Fabregas, not Nasri either.
Given Liverpool's current state that isn't a hard feat to accomplish.