Next style when your text has 2 paragraphs in the same paragraph style...?

There is certainly something recurrent in the titles, may be the one or two end of paragraph which precedes them, may be a word (Chapter, Part, etc), may be a punctuation, …
In this case we can apply the "Text" style to the whole text and then use the search-replace to apply the "Title" style by detecting the recurring element.

As jmlevy pointed out, you're reaching a limitation of the "Next Style" feature in InDesign. It requries that you're text be consistent and doesn't adapt very well to variability. The soft return can help but I prefer not to use that option because it's not fool proof. I'm curious, how is the text getting added into InDesign? Are you importing from another source? If so, we may be able to employ a different solution to achieve the results that you want.

If you're typing the text manually, then you could still use Next style, you'd just need to add a couple more styles. For example, add a body1 style whose next style is body2.

Let us know more details and we'll try to help.

The next style feature works well if you repeat the same pattern: One title paragraph, then one body, then one title and so on. If your body text may have more than one paragraph, you can either:

• define the next style after body text as “same style” and you will have to select ech time your title and all the following body text paragraphs
• or as you say, use a forced line break but this will work only if your body text is left aligned, not justified and if you do no need spaces between the body text paragraphs