The basic structure of my page is
body
div id="content"
nav
article id="spa"
noscript
I searched the docs page for noscript but found nothing. I'm not even sure what the error message is suggesting I should do since the noscript tag is already inside a body tag. The page displays and works properly. When js support is turned off the appropriate message is displayed. I tried moving the noscript tag to just below the body tag but the same warning is issued.
As part of posting this message I took the contents of my html page, including the open and close body tags, pasted it into jsFiddle and it came up clean. This may be specific to Visual Studio 2012 and the JSLint.VS2012 extension. I also didn't see a way in the JsLint options to disable this check.