I also had a randomly scrolled up convo at one point, but couldn't reproduce it in anyway or haven't got the smallest clue how it happened and thought it was probaly my own fault (accidental cursor clicking in the convo)....
dunno if at that time I had a toast popping up, but it might well be possible (my pop3 is checked every minute and I recieve mails round the clock
)...
the convo wasn't scrolled up to much, a handfull of lines, so again it might be this...
So kind-of: confirmed
MSN Messenger 6.2.0205
Latest Plus! beta
Win XP SP2 and the whole yickyack...