This is just more of the same old speculative unsubstantiated theory.
The currently accepted fact is that Sheila and June were found on the floor as per the photographs which are available and as per police officers witness statements.
Yes there is a note by Ann which conflicts with this but is in itself based on hearsay and is not considered stronger evidence than police officers witness statements.
Mike says there is a photograph of Sheila on the bed, personally I won't accept that until I've seen it, nor am I convinced that it even exists anywhere outside of Mikes imagination. In any event even if such a photograph exists it still wouldn't necessarily prove anything in it's own right, what it would or wouldn't prove can not possibly be interpreted from a 30 second glance at this alleged photo on somebody else's desk several years ago. If it's such a smoking gun then what the heck are the defence doing about obtaining it?
Mikes theory on June originally being found on the bed and then propped up against the door just seems ludicrous to me, especially when it's only based on liver mortis patterns which are already consistent with her body being found as reported.