Is the recommendation to include CSS before JavaScript invalid?
Not if you treat it as simply a recommendation. But if your treat it as a hard and fast rule?, yes, it is invalid.
From https://developer.mozilla.org/en-US/docs/Web/Reference/Events/DOMContentLoaded
Stylesheet loads block script execution, so if you have a
<script>
after a<link rel="stylesheet" ...>
the page will not finish parsing - and DOMContentLoaded will not fire - until the stylesheet is loaded.
It appears that you need to know what each script relies on and make sure that execution of the script is delayed until after the right completion event. If the script relies only on the DOM, it can resume in ondomready/domcontentloaded, if it relies on images to be loaded or stylesheets to be applied, then if I read the above reference correctly, that code must be deferred until the onload event.
I don't think that one sock size fits all, even though that is the way they are sold and I know that one shoe size does not fit all. I don't think that there is a definitive answer to which to load first, styles or script. It is more a case by case decision of what must be loaded in what order and what can be deferred until later as not being on the "critical path".
To speak to the observer that commented that it is better to delay the users ability to interact until the sheet is pretty. There are many of you out there and you annoy your counterparts that feel the opposite. They came to a site to accomplish a purpose and delays to their ability to interact with a site while waiting for things that don't matter to finish loading are very frustrating. I am not saying that you are wrong, only that you should be aware that there is another faction that exists that does not share your priority.
This question particularly applies to all of the ads being placed on web sites. I would love it if site authors rendered just placeholder divs for the ad content and made sure that their site was loaded and interactive before injecting the ads in an onload event. Even then I would like to see the ads loaded serially instead of all at once because they impact my ability to even scroll the site content while the bloated ads are loading. But that is just one persons point of view.