I believe solution to this is simple: always switch to kernel-owned
console during suspend. (swsusp does it, there's patch for S3 to do
the same). That way, Xfree (or qtopia or whoever) should clean up
after themselves and leave the console to the kernel. (See
kernel/power/console.c)

Not very helpful on embedded systems that use the framebuffer without the 
VT console.