When creating new action tracks, you'll occasionally be required to pick a workflow state. If you have deactivated workflow states those will also show up in your standard list of workflow states in your action tracks. This can make it difficult to discern between states to choose from, particularly if the names are the same.
This one's an easy one. Just jump back to your workflows, and click on the deactivated state. After the name append some sort of identifier. I use "(deactivated)".