Solaris X Window System Developer's Guide

Stacking

When you raise a window, it does not matter if the window is an overlay window or not, it will raise to the top of the stack. If you lower a window, it does not matter if it is an overlay window, it will lower to the bottom of the stack.

This brings up the confusing notion of an overlay window being below an underlay window. This actually happens all the time. This is because the X server is enforcing the simple stacking policy, and it will do whatever is necessary to make that overlay window appear below the other windows, even if it has to software clip it.

Problems are best avoided by using the underlay-parent overlay-child model. That way, an underlay-overlay pair is treated as an entire application from the parent window, and it raises and lowers together.