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`orca serve` publishes a ready graph under HEADLESS_RUNTIME_WINDOW_ID with no BrowserWindow behind it. `shouldCreateInBackground` only degraded when the create was renderer-backed, so any focus-requested create fell through to getAuthoritativeWindow() and threw "No renderer window available" — leaving `terminal create --focus` with no workaround on a remote server (#10333). With a worktree selector and no renderer window, a background spawn is the only usable path, so collapse the renderer-backed window check into a plain "no window" check. That is the existing rendererBacked clause plus exactly the missing focus case, and it drops the confusing `rendererWindow === null` indirection (rendererWindow is already gated on rendererBacked). Focus is not lost by the degrade: the spawned pane is still published to the session-tab model and revealed with `activate: true`, which is how a paired client learns about it. Mirrors the in-tree precedent in runCreateMobileSessionTerminal. Headed hosts are unaffected — the clause only fires when no window exists. Co-authored-by: Jinwoo-H <Jinwoo-H@users.noreply.github.com>