I can partially see your point for run of the mill js but with a commonly used library like jQuery <head> is more relevant otherwise you have to throw in many window.onload() function wrappers usually bound to anonymous functions just to "wait". In small cases sure this is not a problem but when a user accesses the $ variable many times that's many more randomly inserted wrappers needed to "wait" and increases both file size and potentially load time, not to mention if someone else gets brought in on the project and sees all these wait wrappers strewn about the place they will have to have more effort to bring them up to speed.