My best guess is that the Guru Meditation happens only after I had done a savestate, but this is not 100% confrimed. When I tried to do this, I would get the Guru Meditation. However I need to automate reboots of the VM because some of the databases that I'm running seem to need it to happen once in a while.
My original plan was to do a savestate, backup, start VM.
It doesn't happen if I do a full SHUTDOWN, but it happens when I try to do a restart from within the VM.