Unexpectedly, recent computer simulation studies [Weis and Levesque, Phys. Rev. Lett. 71, 2729 (1993); Leeuwen and Smit, ibid. 71, 3991 (1993)] failed to find a liquid phase for dipolar hard spheres. We argue that the liquid was not observed because the dipolar spheres form long chains which interact only weakly. To support this argument we derive a simple theory for noninteracting chains of dipolar spheres and show that it provides a reasonable description of the low-density fluid phase.