I mean, yeah, sure. Or for a number of other use-cases. I'd argue the best way is for the client to keep the token in memory over local storage. Of course if you have a tightly coupled app, session-based secure cookie is the best.

I may be misunderstanding you, but I do want to reiterate: if it’s in localstorage, I will hijack user sessions on your pentest.

If there’s a use case to keep session tokens in localstorage, it’s insecure design that’s inherently vulnerable.

What I mean by tightly coupled, is if you can have your Frontend and Backend on the same domain, then yes by all means an httpOnly cookie is ideal. Now days there are a lot of SPA's that don't do that, or that have multiple api services across domains, or you are only writing a front-end and using some backend as a service like AWS amplify or numerous other scenarios that have led us to the concept of stateless authentication. You can still use a cookie in those situations, albeit without the use of httpOnly, which means they are going to be just as vulnerable to XSS as local storage. This is why I mentioned keeping a token in memory (this can be made even more secure with web workers). But since this doesn't persist across reloads, it's not an ideal solution for most leading towards utilizing strategies using refresh tokens/one-time use tokens, etc.