* Fair use: If you are using a newspaper headline for a non-commercial purpose, such as criticism, comment, news reporting, teaching, or research, you may be able to use it without obtaining permission from the copyright holder. However, you must still give credit to the original source.
* Expired copyright: If the copyright for a newspaper headline has expired, it will be in the public domain and you can use it without obtaining permission.
* Abandonment: If the copyright holder has abandoned the copyright to a newspaper headline, it will also be in the public domain. Abandonment can occur if the copyright holder does not take steps to protect their copyright, such as by failing to renew it or by allowing it to lapse.
If you are unsure whether a particular newspaper headline is in the public domain, it is best to err on the side of caution and obtain permission from the copyright holder before using it.