OK, that makes sense. I guess then I'm not sure whether this was meant as a criticism of the title or just pointing out the feature. Since "Texas Appeals Court" is a single entity, it seams like a reasonable way to begin the headline, especially given the general convention that headlines avoid unnecessary prepositions such as in the possible alternative "Appeals Court in Texas". To my reading, the garden path ends at the third word, which doesn't seem too terribly bad for a headline. Perhaps I'm missing some subtle annoyance though.