The way this is documented, in §4.5.1, Creating a Stack, is like so:
Select the notes you wish to arrange into a stack. The first note you select
will not move, and subsequent notes will be placed under the first note in
order of distance from the first selected note.
So it shouldn’t matter much which method of selection you use, the only important one is which you choose first. For the most part the items will be gathered as they are listed visually, but I suppose in some weird cases it might feel random, like if stuff is scattered around chaotically in a cloud around the point you want to gather them under.
Shouldn’t take but a quick nudge here or there to influence the order, or if you find it easier, use the instructions found in §4.5.6 to re-order the stack more easily after it is created.
Honestly I find that a lot easier than messing with text lists, and particularly rich text lists, which in the Mac text engine, are rather poorly designed and buggy.