In org-mode in emacs,
M-<RET> will add either a new heading or if your insertion point is between a list item and a heading, it will add a new list item. This is not always desirable. To add a new heading try
I only discovered this as I got frustrated with org-mode insisting on adding an item to the list rather than creating a new heading. The emacs way around problems like this is to prefix the command with
C-U to make it do something slightly different.