What are baseline expectations for the number of open file handles with Docker in WSL2

Where do you get that message exactly?

I think you can get the limit by running the following in the WSL distribution:

sysctl fs.file-max

or

cat /proc/sys/fs/file-max

but that should be way bigger than 436

Those are related to the WSL integration. If you disable WSL integration, you will probably not see any Docker related process since Docker will run in its own WSL distribution even if you have integration.