This property returns the Map's total number of selected features belonging to editable layers.
I've not tried this, so it may not work as you intend?
Why not listen out to the IEditEvents.OnSelectionChanged Event? If the selection exceeds your criteria you set a global boolean to TRUE so when the user attempts to delete the features your IEditEvents.OnDeleteFeature Event tests the boolean? If TRUE then follow some other logic?
Duncan
The IEditor has a SelectionCount property, also