In a truly optimized implementation, the method for choosing pivot should depend on the array size - for a large array, it pays off to spend more time choosing a good pivot. Without doing a full analysis, I would guess "middle of O(log(n)) elements" is a good start, and this has the added bonus of not requiring any extra memory: Using tail-call on the larger partition and in-place partitioning, we use the same O(log(n)) extra memory at almost every stage of the algorithm.