Headline bias is the first tier and most prevalent form of media bias. They know people see the headline first, and most people don’t read the article for full details. Many times the headline is 180 degrees out of phase with the content of the article.
Sometimes it’s more subtle:
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Ted Lieu Accuses NY Times of ‘Intentionally’ Writing False Headline
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NY Times Intentionally Writes False Headline, says Ted Lieu