You would think so wouldn't you. I had this same issue last week, unfortunately I had to wait until the database was not in use ( lucky it's not 24-7 ) before doing so. I think the problem is that on compilation it has to enable to check it's validation, however I could be wrong. SOL
I'm only guessing but my guess work generally works for me.
why do you want to create a trigger that is disabled. check it like a normal SP for business logic. then when you close down for maintenance you can create and disable it.
seriuous i don't understand the need for a disabled trigger
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