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I can imagine the conversation now:

Headline Writer: "Hey, I can't think of a word that will fit in the headline."

Editor: "How many letters?

Headline Writer: "Four. Hmmm. How about 'sidewalk.'"

Editor: "'Sidewalk'... I like it. But wait! Too many letters!"

Headline Writer (thinks, then): "Oh yeah. Ummmm... 'road'?

Editor: Nah.

Headline Writer: 'Boil'?

Editor: Nah.

Headline Writer: 'Turf'?

Editor (snapping fingers): Brilliant! You're going to go far in this business, kid!

"Judge Refuses To Turf Gay Governor"

Related: the many definitions of the word 'turf,' none of which are relevant to that headline.