Why does placement of facelift incisions at the temple vary?

Looking at various photographs of different facelifts, sometimes the incision at the temple (above front ear) is well-hidden in the hairline (and often closed with staples), but sometimes it seems to curve around the hairline (and closed with stitches) so that it is much more visible. Does it depend on the surgeon's technique or the type of facelift (mini, full, macs etc)?