None of the style guides I've seen or Tailor enforce anything specific here other than max line length. Code Complete (the book) spells out both of the options above and lets you decide. 

Generally speaking, I usually opt for the first since its easier for me personally to parse quickly when I see it. I usually only use the second form when I have a really long param that I want to inline in a return statement or something.

For example, I would use the second form for something like this:
```ruby
return some_method_call(
  "a really really really really really really really ridiculously long string")
```

I don't have strong opinons here though.