Lighting Positions like to be Hybrid Symbols, you don't need to leave the text floating there - rather draw a line or rectangle etc. to represent your LP in Top/Plan view, select both and create a symbol. Leave Instance in place and convert 2d Layer Plane objects to Screen Plane objects.
Then Spotlight>Object Conversion>Convert to Lighting Position.
'twould be nice if you could bypass the create Symbol step, seems logical.
I take your point however that when no 2d geometry is present or desired the label should still be visible in 3d views, and the 3d gemoetry should be visible if there is no 2d geometry available. This should now be possible with the new Layer Plane functionality of VW2011. A wish list wish might make it so.