Photoshop :: Type Layers

We're trying to do a simple thing like using text to filter an image. We've loaded a jpg image, changed it from being background, and try to add a type layer (as instructions said would happen). However, when we type, there is no new layer in the Layer palette, and thus we can't use it as a clipping filter.

I know about how some images don't create type images, but we've even tried creating a type layer with no image background. It just won't create a type layer.