Why use SCOPE instead of TH

The question came up on tonight’s call as to why an author would use SCOPE instead of TH for a data table with only one level of row or column headings.  I thought I would share a couple of scenarios I have encountered with some regularity.  I agree these are not *great* reasons for the technique, but I am comfortable asserting they are at least minimally acceptable.

1)  The author is not comfortable with CSS and finds the default formating effects associated with TH to be undesirable.  Adding a SCOPE attribute to a TD tag is a straightforward fix.

2)  TH tags do not *always* appear in the topmost row or the leftmost column.  The value associated with a SCOPE attribute programatically resolves any ambiguity as to if a TH applies to a row or column.