Well, the easiest (and probably most common) is "everyone has an equal chance." Into a 2-person grapple, there's a 50 / 50 shot of hitting either one. Into a 10 person grapple, there's a 10% chance of hitting any given target.
The next most common is based on size. Basically, pick the smallest size in the melee. Give them a value of 1. Each size category larger doubles the weighting. Then, determine randomly based on each potential target's share of the total weights. For grapples of identically-sized participants, this works out identically to the above.
Consider the following examples:
1. Two humans (Size M): Each has a value of 1, and is therefore 1 / 2, or 50% likely to be the target.
2. One halfling (S), one human (M): 1 (Halfling) + 2 (Human) = 33% chance of hitting the halfling, 66% chance of hitting the human
3. One halfling (S), one human (M), one ogre (L): 1 (Halfling) + 2 (Human) + 4 (Orgre) = 14% halfling, 29% human, 57% ogre
A variant on the above is to weight the intended target as one size larger.