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It isn't consistent. For example, lots of the pages at www.boston.com do grab focus, but then don't when I open the same link in a background tab a second time. Try this one. It just did:

http://www.boston.com/business/artic...rysler_source/

In this Google Images search page of Tyra Banks (warning: possibly Not Work Safe! Quite tame IMO but pls don't click if you might be offended), I clicked on the top left photo which opened in a background tab and then grabbed focus. I thought it was javascript doing this but how can that happen when it's just a JPEG?