Huh?
The problem is not one of "randomness," it's one of orbital mechanics.
So two bodies can't have a gravitational interaction which throws one off of the plane of the ecliptic and just 'happens' to also have a circular orbit?
We've only got one body here to go on. If it was an entire accretion disk remnant (lots of co-planar bodies in circular orbits) off of the plane of the ecliptic, then we'd have a major theory malfunction.