I am not 100% sure that what I'm describing is true but here is my impression:
If you use #selectPath:scrollToSelection: to select an element of a tree and scroll to it before opening the presenter, it will save the scrolling as a defered action.
Once you open the presenter, the layout will build the sub elements and execute their defered actions. But then it will apply the layout of the "parent" presenter. Thus, the defered scrolling happens when the layout is not done yet and it fails because the extents of the tree is not the final one.
Then when the presenter is opened, the scrolling is wrong.
I have the impression this is what is happening