The KDE window manager (kwm) has a window placement policy called "smart", which tries to position new windows so that they have the least possible overlap with existing windows. When the "kdebase-1.1.1-2" package, this policy is not applied to Netscape's windows. Instead, newly mapped windows are always placed in the top left corner of the screen, even when the window placement policy is set to "smart". (This might apply to all Motif applications, or only to Netscape. Since Netscape is the only Motif application on my box, I can't test how broad the problem is.) Note: this is a *regression*! In "kdebase-1.1.1-1", the "smart" window placement policy worked just fine for Netscape windows.
For what it's worth, this problem also appears in the kdebase-1.1.2-6 rawhide RPM that was recently released.
netscape hardcodes its window placement, and kwm can do nothing to override this. the window manager can only make a suggestion. Unfortunately, this will probably never be fixed.
Window managers reparent application windows. Thus, ultimate authority for the placement of a window does rest with the window manager, not with the application. It is applications that suggest positions, and window managers that choose to respect or ignore them. So KWM could certainly override Netscape's suggested placement. (In fact, that sounds like an excellent candidate for a configuration option.) Also, consider the fact that KWM did use its own placement policy in the "kdebase-1.1.1-1" package. This is a regression that first appeared in "kdebase-1.1.1-2". The Netscape application did not change in that time period. Clearly, then, the window manager does have a say in where windows are placed.
I believe the concensus was to allow programs which specifically requested a window position to have it; this allows for better session management. This has not changed even in the latest versions of KDE 1.1.2's CVS tree.