Theortiically, there is no position that they can't be mounted in, as long as that position is fixed. Horizontal, vertical, tangentially....
When they are spinning, they react as a gyroscope would to motion. (OK, I could get into a long discourse here about coriolis force, precession.... But that would be boring.) Get out a bycicle wheel, hold it in a position, (any position) and get someone to spin it. Now shift the axis... You'll get the 'drift'.
I have long been of the opinion that inside of a PC case, they should be mounted vertically for optimised air flow. All of the major drive array MFG's mount them that way, and even some of the smaller NAS devices as well. But find me a PC case that deviates from the horizontal norm... Go figger.