I was offered 23H2 this morning (by seeking) and I upgraded.
Now, the issue sometimes happens and sometimes doesn't (each with brand new File Explorer window instances)... when it doesn't happen, you can still see the File Explorer window flickering/refreshing in the background when it would normally pop-over what I'm doing:
When it "works" (notice the flash in the backgrounded File Explorer window at the 10 second mark): sometimes works (vimeo.com)
When it doesn't work (same old nonsense, notice the background explorer window take over my screen at the 7 second mark): sometimes doesn't work (vimeo.com)