On Ubuntu 19.10 I'm experiencing the same thing as the comment above:

###################################
Jan B (hey-e) wrote on 2015-04-08: #143
I have a laptop and a monitor as secondary display
...
Every time I switch back from only using the monitor (laptop display disabled) 
to using the laptop display as a second screen – I need to rearrange the 
displays. By default they are side-by-side but I always want the monitor above 
the laptop display.
###################################

I don't have Ubuntu 20.x installed at the moment to confirm whether it
happens there, too.

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https://bugs.launchpad.net/bugs/1292398

Title:
  Second screen position isn't saved from one session to another

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