This could be a duplicate of 494096:
Clicking the title of a window is bringing a window underneath it into focus
https://bugs.launchpad.net/ubuntu/+source/metacity/+bug/494096

It should be fixed in 10.10, but so far, it doesn't look like a fix is
released for 10.04

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https://bugs.launchpad.net/bugs/559202

Title:
  xorg wrong window selected when clicking title bar

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