Well, it really depends upon speaker placement possibilities.
If your customer wants a home theater in the middle of a large room and you dont have any walls nearby, then you don't have a choice. I've used ceiling speaker for the rears, and a couple times for the center. It works OK, but make sure you have pivotable tweeters!
I was thinking more along the line of an overhead channel--one that would be matrix from the two side channels using a SMART Circle Surround device. This would be the same as a rear surround only directly overhead. Helicopters would sound great. Sounds coming from directly behind would sound funky.
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