I was just going by the photos I've seen. Being capsized is marginally better than having the superstructure knocked off.
It still doesn't look upside down to me because I can't see any evidence of the subsea structure floating at the surface. But maybe it was a clean break.
My hunch is Noble's floater that got loose and came with abt 2 miles of Typhoon may have been dragging anchors or cables that sheered off enough of Typhoon's six tie-down cables to let it bust free. From that posture, it would have been a sure bet to capsize, being top-heavy. Noble's rig was thought by some reports to have actually collided with Typhoon, but Noble got a retraction on that from Rigzone. Whatever, prolly sumbody go'n get sued. Here are URLs on some other nifty rig wrecks from Rita:
http://www.rigzone.com/news/image_detail.asp?img_id=2583&a_id=25600
http://www.rigzone.com/news/image_detail.asp?img_id=2582&a_id=25600