An excellent suggestion! I found that you can arrange the icons given some
caveats.

'Line 1: Open a workbook
Workbooks.Open Filename:="C:\Work\MyWorkbook.xls"
'Line 2: Minimize it
wb.Windows(1).WindowState = xlMinimized
'Line 3: Activate a window that I know is already open and minimized
Windows("CommonCode.xls").Activate
'Line 4: Arrange the icons
Windows.Arrange ArrangeStyle:=5
'Line 5: Put the focus on an open window
Windows("AnotherWorkbook.xls").Activate

The code on Line 4 will compile regardless. However, execution will halt
with a run-time error unless the focus is on a minimized window.