I think this is as much about brake design/foibles as anything else, some are much easier to bleed and less likely to create problems for you, and those you can bleed with the pistons fully pushed back for simplicity and without any worries. Others are not so well designed and more temperamental and for those I reckon it’s better to bleed with pistons out, then as a final step push teh pistons back with the reservoir/top syringe open. It shouldn’t really make a difference but it does.
(I’ve been using the same brakes for a decade so I keep kind of forgetting that not everything is as well made or easy to bleed as they are, it’s such a solved problem that it’s kinda infuriating that they keep managing to unsolve it)