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It will only scroll the items far enough to make the last expanded tree item visible (otherwise blank space would be displayed in the Data Explorer, which would not be useful). So if there aren't enough items below the item you are "going to", then it won't actually scroll the item to the very "top" of the Data Explorer. It also won't scroll if the Data Explorer is displaying all expanded tree items already (doing so would unnecessarily hide items which also doesn't seem very useful).
Might this explain what you are seeing, or is it actually not scrolling the Data Explorer Pane when it could/should?
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