So far I have been happy with btrfs instead.
I was able to get it working (with a few setup issues) with a RAID 1 mirror: https://github.com/microsoft/WSL/issues/6711#issuecomment-10...
(Forgive linking in the middle of a Github issue. Everything ended up working with the latest updates and being an administrator.)
Have had zero hosed drives with ZFS. Although with ZFS not being supported in the kernel, it's fairly hard to do a ZFS-on-root setup unless you're using Ubuntu.
YMMV.