It appears to me that there are as many definitions of orneriness and toping from the bottom as there are couples engaging in the activities. What one may consider topping from the bottom another may look at as orneriness. What works for each couple I believe is the important issue.

If the Dom accepts the orneriness as just that and possibly lets it influence how he deals with his sub it appears to me that would be the ideal situation in that instance. However if the reverse were true and he resented the implication of the orneriness then he may, in fact, consider the same act as trying to top from the bottom.

Whatever works for each couple is how it should be played IMO.