It shows up seemingly randomly.
This sounds like a limitation of WSL/Wayland/Weston in general. I can reproduce the same behavior just running a basic xterm -- The window placement is seemingly random on each launch.
Under Linux, if an application doesn't specify its own placement, the window manager is responsible for doing so. Gnome/Mutter has implemented a Smart Window Placement feature, which is the behavior I believe you are likely seeing on "regular" Ubuntu.
On WSL, support for graphical apps is provided through Wayland/Xwayland, with the Weston compositor, through an RDP backend to display it in Windows. Weston is pretty "basic", since it is really just considered a reference implementation.
As a workaround, I tried to use devilspie2 as mentioned in the Ask Ubuntu answer linked above, but that doesn't work on XWayland under Weston either, unfortunately.