No, I don't think that it's a better design. SFML's API should be designed to make sense, not to publicly reflect what internal dependencies (Win API, X11 etc) require.
Without checking, but there should be definitely ways to minimize and maximize a window without recreating it, as that sounds kinda insane.
If a window recreation is required, though, then it should be evaluated if that yields issues or can simply be done.
In general this should be transparent to the user, though.