Sure, with ZFS JBODs are the preferred storage. Let ZFS do end-to-end management of the storage, from the file level to the raw disk blocks. That way it can do it's end-to-end error checking and possible correction. If you do RAID1 in hardware ( really just firmware in the storage box) you trust that software to detect all problems and correct them or report them. That software may not do checking to see if both branches of a mirror are correct and pass on bad data upstream. ZFS will detect this because of it's checksums, but it will not be able to correct this. If ZFS is doing the mirroring it will detect it and read the other mirror, if that checksum is ok, it will correct the error and continue.