In the <input type="file"/>
element, in modern browsers the focus goes to the button that invokes the file selection dialog. Hitting enter in that instance should invoke the dialog instead of submitting the form. IE, of course, does things their own way. I would be inclined to conform IE to standards rather than the other way around.
But more the point, why would you ever deliberately submit the form if that field hasn't been filled? It's a validation error at best.