Didn't say the headline was misleading but for a lot of us a giant DUH when you read it. Of course if you read that 1997 article in conjunction with that headline, or again in 2003 when they came out with almost the exact same thing, it really makes some of us scratch our heads.
George Will did a nice piece on it back in 2003.
“Last week, the New York Times did it again. Year after year, the same Times reporter, Fox Butterfield, writes a story with some variant of the same theme. This one in last weeks's story. Notice the secondary headline: 'More Inmates, Despite Slight Drop in Crime.’
“'Despite?’ Perhaps there is a drop in crime because more criminals are in prison. Three years ago, another Times story, again the word 'despite:’ 'Number in Prison Grows Despite Crime Reduction.’
“At the Times, it must be unthinkable that crime is reduced by increasing imprisonments. A 1997 Times story was headlined: 'Crime Keeps on Falling, but Prisons Keep on Filling.’ The Times thought it was odd that when imprisonment increases, crime decreases. The Times won't consider that punishment cuts crime. In January 1998, another Times story, again, used the word 'despite:’ 'Despite a decline in the crime rate over the past five years, the number of inmates in the nation's jails and prisons rose again in 1997.’ Eight months later, another Times headline: 'Prison Population Growing, Although Crime Rate Drops.’
“The Times was mystified by the correlation between more criminals in jail and less crime in society. In 1999, the Times reported in amazement that, 'The number of inmates in the nation's jails and prisons rose again last year...though crime rates have dropped.’ [on screen graphic of the story’s lead sentence showed these words in the ellipses: “to a record 1.8 million.”] Again the Times was mystified. Crime rates and imprisonment rates were moving in opposite directions.
“I suppose that is mystifying -- if you believe, as some liberals do, that punishment is ineffective at preventing crime. Is the Times consciously pushing that political point of view? No, not consciously. Unconsciously.
“The Times may be so hermetically sealed in its bubble of beliefs, it may not recognize that those beliefs are coloring its reporting. But is there no one at that paper who can burst that bubble?”