Attached is a patch which causes emacs to try to create a new GUI frame if there are no existing frames and the current TTY is unusable.

This only works if emacsclient tells us which display to use, and currently it only does that if --display=… is specified.  This is fine for my purposes, but we might want to look at having it pass along $DISPLAY in more situations.

I have submitted copyright assignment paperwork but am currently waiting to hear back.

-- 
Peter Oliver