I was just about to report this very issue for Ubuntu 9.10, and have to
chip in that the above is patently incorrect with compiz
1:0.8.4-0ubuntu2.1.

A minimised or closed window pulls focus in order to minimise or close,
and only when this is done does the window behind regain focus.  The
behaviour is rather weird and jarring.

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Undesirable focus while closing or minimizing
https://bugs.launchpad.net/bugs/189329
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