> Granted, I've never ever encountered these, but still -- it's not as simple as you make it out to be.

There's one and only one of these cases which I've seen (and I'd see) happen: `return`, for users of Allman, while that is completely nutty (just as Allman) some people will write:

    return
    {
        key: value
    };

even though they're defining an object literal not a scope. The result is returning immediately (undefined) and dropping the object in space.

`throw` would be really weird, it may happen with a labelled break or continue but I've yet to see those ever used at all (so a user of these probably wouldn't fuck up the label, plus that label would become a bareword which most static analyzers would trivially see) and postfix operators outside of continuated expressions (e.g. function calls) are unlikely to be split.

I've been bitten more often by not having inserted semicolons than by any of those.