Is it possible to have open images in Photoshop but none of them be the activeDocument?

And is there a batchPlay command or API that does this?

The reason I ask is that the problem of UXP plugins stealing focus from Photoshop is solved if batchPlay chooses a different document or duplicates the current document. Focusing on a different document restores focus to Photoshop. Keyboard shortcuts work again. I’m thinking that making all documents inactive and then reactivating the previously activeDocument might also return focus to Photoshop in the process.