Behavior still exists in precise.
Additionally as it's not seen as an active window, it's open windows do not 
appear in the application switcher.
Compiz is the current active window manager, I have not yet tested other de/wm 
configurations.

I also experience Bug #998198 which may have some relation.

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https://bugs.launchpad.net/bugs/979285

Title:
  Unity in Oneiric Gedit does not let gedit act as "active", causes
  opening of new documents when trying to return to gedit window.

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