Yeah. I've seen some like that, but really at that point I would look for another source, or make it clear that it's editorialized title.
I think something to consider really with all rules is there's always wiggle room and edge cases. With every rule, to cover all those edge cases, it would get so convoluted and long that nobody would read it.
Perhaps for the communities that see this kind of rule as appropriate, it should be more so "Avoid editorializing Article Titles"