Take Rich Note vs. Plain Note

In non-rich-text applications like TextMate, only “Take Plain Note” is available from the Services menu; “Take Rich Note” is dimmed.

I’ve committed the command-) “Take Rich Note” shortcut to muscle memory, and it’s inconvenient to stop and think, “Which app am I in? Is there rich text?”

Why not let Take Rich Note work in plaintext apps, and create a richtext note that happens to not use any richtext codes?