Sarah Kliff's title is a little more neutral, but if you read this story, and think about it, it's clear that one title is misleading and the other is accurate. It's true that both titles are technically correct, but one leaves out relevant information (the fact that Maryland's rates are already pretty low), and, therefore, provides no information about how Obamacare will affect premiums.
I would've given the paper a pass if it said something like "Rates could fall by as much as X %".