[fw-mvc] Ensuring that Zend_File_Transfer will always return an array

I'm implementing one of these dynamic "add another file" thingies via javascript, so I can never be sure how many files my clients are uploading. That being said, my code is expecting an array. If there is only one file uploaded though, getFileName returns a string.
I'm currently using Zend_File_Transfer through the form helper, and i've set "setIsArray(true)". But that doesn't seem to help.