The owner (or parent) of a modal dialog may jump behind an overlapping program when the modal dialog is dismissed. Note that this behavior is quite random. I can reproduce this jumps behind problem at 70% of the times using the test program, HelloModality, in toys/HelloWorld. All you need is to bring up an application such as a cygwin window, run HelloModality, and a create a few modal dialogs over the cygwin window. Then dismiss the dialogs in order. You should notice that, sometimes, the cywin window might jump to the front.