Historically, ckEditor has been problematic when "autoParagraph" is enabled, as it creates unwanted empty <p> </p> tags.
However, with autoParagraph turned off, the editor is inconsistent with how it generates HTML. For instance, if a single paragraph is entered, it will not be wrapped in <p> tags until the enter key is pressed. This causes display and styling consistency issues when some content is wrapped in <p> tags and some is not.
In newer releases of ckEditor, the autoParagraph behaviour is fixed and works as desired, so it should be turned on again by default in Preside (as of 10.9).
It should however be a customisable option, so it can be turned off globally in Config.cfc to retain the existing behaviour (useful if an app has not been fully checked to see if this causes a breaking change - which it shoudln't, though).
It should also be customisable on a per-editor basis either via a preside object property definition, or in a form definition.
At the same time, we could add a per-editor option to change the behaviour of the enter key to add a new line rather than a paragraph.