How to write a misleading headline

Dr. Dre Loses Round In Death Row Court Battle. When I first saw this headline, I thought, "What? Dr. Dre on death row? What? How? Where? Is this another Dr. Dre?" Turns out I can step down from red alert; Death Row is the name of a record label. Some of you may have already known that. But for those of us who were unaware, definitely this headline is unclear. I'm not sure what the spacing/character count constraints were on this headline but I think "Dr. Drew loses in record label court battle" would be a more clear headline as to what's actually going on.