I see a lot of homes where remodels have occurred, where an electrician will change the breaker from 20 to 15 to add some 3-way wiring with multi-location dimming on all gangs, for example and use 14 to make is easier to wire up the box. Crammed behind dimmers 12 ga is a pain, unless you use the metal boxes with the mud ring that drops a 3 gang down to two, or 4 to 3, etc. Especially when the last sparky used the switch box as a j-box for other circuits.
Even if there are no dimmers in the bid, there may be later. dimming saves a lot of energy, and can increase bulb life 5 times. there aren't that many loads in ceiling lighting where 20 amps is necessary. That would usually cover an entire house, which I would never do, since it means if the circuit goes, there are no lights anywhere.