I have to respectively disagree. The Apple HIG, the old one from the
MacOS 7 days has a pretty solid explanation for why this is confusing to
the user backed by HCI data not just a hunch. If you can find a copy the
relevant section is chapter 4 entitled "Toggled Menu Items".
I'll just quote the paragraph that is relevant to is here but I
encourage you to go read the whole section, you should be able to find
the book online.
0. Don’t use one menu item with a toggled checkmark to indicate the
presence or absence of a feature like a grid or a ruler. It’s
unclear whether the checkmark means that the feature is in effect or
whether choosing the command turns the feature on.
