The construction plane sounds good -- as long as we can define it by specifying any three points. I tried ArcContinue, but it's not really a good solution for what I'm trying to do. But for now I can get around by using a 3-pt circle along with some construction lines.
Yeah, once construction planes are in there will be a variety of methods to define it, by 3 points, normal to a line, along an existing planar object, etc...