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Maybe pressing the Return key should commit an active edit (as the Enter key currently does). However, if no edit is active and the action is only selected, then have the Return key create a new action with the cursor in the title field, ready for editing.

The practical difference is that you'd have to hit Return twice to create a new action if you're currently editing some other action (once to commit the current edit and once again to create the new action).

Would this be acceptable?

-Dennis