There is a basic, but interesting thread at Search Engine Watch Forums named Does Title Tag Need To Come First? The question is more detail is, does the title tag within the HTML code of a page, need to come at the very top or can other code be above it, without it affecting search engine rankings?
There is a core rule in SEO that your keyword specific content for the page, should be as high up in the source code as possible. Meaning, your introduction content and your header tags, should be as high up within the source code as possible. There is also the belief that these keywords are important to have in the visible content as high as possible, not just for search engines but also for your readers.
But does that apply to the title tag and meta data for the pages? Good question.
Danny Sullivan and David Wallace both say it should not matter. But for standardization purposes and having clean code, it might be best to place the title tag at the top. But in terms of ranking, they both say, in the past it has not mattered and it probably doesn't matter today.
Forum discussion at Search Engine Watch Forums.