I am currently operating with Monterey, 12.6.5. I routinely keep 20+ documents open in Preview. Whenever Preview quits, whether it is for a restart, an intentional quit, a crash, or a forced quit, it reopens with a different set of documents than were open when it quit. I can't tell when this list of 'active documents' was set – it seems like a random group of docs that were open sometime between the prior launch and the recent quit.
This didn't always happen with Preview, but it has been happening since at least version 11, Big Sur, and it feels like earlier than that. I have tried debugging this several times, with no luck. I long ago unchecked the option System Preferences → General → Close windows when quitting an app . That hasn’t done anything.
I also boosted the System Preferences → General → Recent Items list to 30, and it did nothing. This didn't seem to be a limiting factor anyway; my last setting was 10 and Preview would reopen with more than 20 documents open at a time – just not the ones open on the last quit.
Any ideas on how to address this? It's not the end of the world, but I use Preview to review and notate papers as I write my own work, and the active open list is helpful. Not infrequently, I'll have changes that were not saved in one or more of the open documents. While that's clearly on me, it just adds to my frustration. I don't think it's related to the problem, but offer it in case it might be.