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Carlos JoséCourses Plus Student 12,431 Points
Label instead of heading for CSS styling ?
I guess that Nick chose the label element instead of a heading element to use the CSS styling used for that element.
Steven Parker221,309 Points
You did not reference any particular course/module/video, but just in general, I would expect the choice of a label or heading would be related to the HTML content.
I would expect a heading to be used with a collection of items, and a label to be used with a single one, particularly an input or control of some kind.