Let $H$ be a Hilbert space. Let $U$ be a subspace and let $E$ be any complement such that
$$ H = U \oplus E$$
I am wondering if it can be said that $U^\bot$ is contained in $E$. If not can it at least be said that $\mathrm{dim}(U^\bot) \le \mathrm{dim}(E)$?
Geometrically the answer can be obvious. Take $H=\Bbb R^2$; writing $H=U\oplus V$ involves finding two one-dimensional subspaces, or equivalently, lines through the origin. The only way one line contains another is if they coincide, so your hypothesis is that there are no nonorthogonal pairs of lines through the origin, which is clearly wrong.
If $U\le H$ is any subspace and $E$ any complement then $E\cong H/U$ (the projection $H\to E$ has kernel $U$), so $\dim E$ does not depend on which complement is chosen.