The attached patch against master fixes the issue on OS X 10.6 by constraining frames to the visible area. Behavior with OS X 10.9+ (and "Spaces") still needs testing. The patch also fixes https://debbugs.gnu.org/cgi/bugreport.cgi?bug=14713, which has reappeared since it was fixed (at least it has reappeared on 10.6). Also CCing Jan Djärv who worked on this area of the code previously (see e61a31bf999b37f32616e5159196d179657ad788).