Trying this in LINQPad shows the sql generated to be the same:
var r1 = Users.Count(u => u.JurisdictionId == 5).Dump();
var r2 = Users.Where(u => u.JurisdictionId == 5).Count().Dump();
and the sql generated:
SELECT
[GroupBy1].[A1] AS [C1]
FROM ( SELECT
COUNT(1) AS [A1]
FROM [System].[Users] AS [Extent1]
WHERE 5 = [Extent1].[JurisdictionId]
) AS [GroupBy1]
GO
SELECT
[GroupBy1].[A1] AS [C1]
FROM ( SELECT
COUNT(1) AS [A1]
FROM [System].[Users] AS [Extent1]
WHERE 5 = [Extent1].[JurisdictionId]
) AS [GroupBy1]
This is using EF 4.2, but this should be the same in 4.1.