From the MSDN page for the BoundingSphere.Contains method that takes a BoundingSphere parameter:
Checks whether the current
BoundingSphere contains the specified
BoundingSphere.
It returns a ContainmentType enumeration which
Indicates the extent to which bounding
volumes intersect or contain one
another.
Specifically:
Contains: Indicates that one bounding
volume completely contains the other.
Disjoint: Indicates there is no
overlap between the bounding volumes.
Intersects: Indicates that the
bounding volumes partially overlap.
If BoundingSphere1 is smaller than BoundingSphere2 then I suppose BoundingSphere1.Contains(BoundingSphere2)
would return a ContainmentType.Intersects result instead of a ContainmentType.Contains result since it doesn't "completely" contain the other. On the other hand, BoundingSphere2.Contains(BoundingSphere1)
should return ContainmentType.Contains since it "completely contains the other."
EDIT: I've updated my answer after reviewing the documentation again. Initially something sounded vague but now I think the emphasis in the enumeration details of "completely" and "partially" for Contains and Intersects, respectively, strengthen my expectations. I can't test this but this sounds reasonable.