Where it actually appears on the page is irrelevant - this is a presentation issue handled by CSS, and Google couldn't care less about that. Ryan is correct that the order in the source code can have an effect, and that it's generally held that content nearer the top of the source code is given more importance. However, I think it's probably a small effect, and Google is constantly getting better at picking out constant sections of the page (ie navigation), and disregarding them in terms of the pages content.
If you're using CSS to make your navigation pretty, then there's actually very little content needed for a menu anyway. You're likely to have lots of tags floating around, but actual content is likely to be just a few words - so not likely to make a big difference.
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