I view this not only as "dumb" but self-defeating. This kind of reader's impatience and arrogance (so sure they're so brilliant that of course they've figured out what the article says) has cost them valuable knowledge or a lovely experience or rewarding encounter.
Believe it or not, this title judging happens even in my world - poetry. I can't figure out why else a 1 to 3 minute read would be read only 50%. Poetry takes time. To absorb the layers etc. But you know this, as a poetry lover.
Their loss, eh? What a world. :)