I use the Openbox window manager with Xfce applications, and for some strange reason during 2023 the Xfce Terminal started opening behind other windows. It must be because of a change in Xfce, since Openbox hasn't been updated forever. The problem only happened if I already had a terminal open which was behind another window. If I had no terminals open already then the new one would always open on top of other windows like it is meant to. This issue occured when using my terminal keybinding and also when clicking the terminal button on the panel.
I just left it and assumed one day it would fix itself, and got annoyed every time my terminal ended up hiding behind Firefox. But it's been long enough now that it looks like I am going to just have to fix it myself.
Turns out that is very easy, I just needed to add a rule to the <applications> section of the Openbox rc.xml to always focus Xfce4-terminal so it is on top of everything else when first appearing:

<applications>
  ...
  <application class="Xfce4-terminal" name="xfce4-terminal">
    <focus>yes</focus>
  </application>
  ...
</applications>