You might have been looking at photos of collected California Juniper. They tend to grow in groups of 3 or so and the base is often a twisting fan
Sometimes the roots don't begin right away and a useful planting angle necessitates that you tip the tree quite a bit. Then the it appears that the tree is almost smashed up against one side of the box, when in fact, the root system is almost entirely at the other side.
That's the only reason I can think for this type of placement.
Regards,
Matt