labels and AT (was: Proposal for <figure> graceful degradation)

In http://lists.w3.org/Archives/Public/public-html/2007Sep/0375.html
Maciej Stachowiak wrote:

> 3) Lachlan Hunt points out two possible problems
> with using <label>:

>     3.a) It may interfere with assistive technology
>          to have labels  that don't contain a form
>          control and are not associated with a form
>          control via "for". Neither of us was sure if
>          this would be a real  problem.

For JAWS, from their website,

http://www.freedomscientific.com/fs_support/BulletinView.cfm?QC=565

In particular, the first question

    ... Is there an optimal way for me to label
    form fields for accessibility?

    A: Yes, use explicit labels or title attributes.
    Do not use implicit labels.  For example:

    <label for=fname>First Name</label>
    <input id=fname name=fname type=text>
    -OR-
    <input title="First Name" type=text>

    Avoid the implicit method shown in this example:
    <label>
    First Name
    <input type=text>
    </label>

I also note that the windows-eyes support group did not second this,
and said it was probably just a quirk of JAWS.

-jJ