Yeah, but a big part of the Goebbels game is to create an overall picture of separate events that paint the larger falsehood you want to create. For anyone other than the single-digit percent of people who decide to click on the article, the headline forms one more little thing they're scrolling past that paints an overall picture of "Biden is malicious on immigration and trying to hurt people," which I think is actually one of the most successful totally-made-up realities they've managed to get into the public consciousness to try to depress support for him among people that would otherwise be inclined to.
I'm a little suspicious of the meat of the article, too -- like how much connection is there between these particular lawyers who made this filing, and Biden (presumably he didn't weigh in on this particular case, but are they even State Dept lawyers? The article says so, but I thought usually the lawyers for this kind of thing would be rank and file DOJ immigration lawyers, maybe I am mistaken)
Are the tattoos that they said justified non renewal really totally innocent non MS13 tattoos that the racist immigration apparatus freaked out about, as his lawyers are claiming? (easily possible but also not guaranteed to me simply because his lawyers are claiming it)
But the meat of the article is maybe at the "IDK I have some questions" level, whereas the headline is what'll have honestly most of the impact on the public consciousness, and it's well up into "get the fuck out of here with that explicit propaganda" level.