This doesn't reproduce for me - I have a rich text box on my form, and added an expression box with an expression to check if the field is blank (my:field1 = ""). It returns true when there is no content in the RT field. If I type content in and tab out, the expression box returns false.
Do you have any other rules that might be hiding your submit button? Or do you need to check the RT box to make sure it doesn't just have a line return or something?