I get your point, but I laid out newspapers and designed ads for newspapers in the early 90s (after getting my Master’s degree in English but that’s another story)— and the writer never wrote the headline. An editor/proofreader did and they were trying to fit a spot physically left open for them. To this day, when people blame writers for bad or misleading or awfully punny headlines I think, “Don’t. It’s most likely not their fault.” Disclaimer: This was the 90s when papers were still physically laid out. This could have changed with the advent of all-digital.