That's why he said misleading rather than an outright lie. He is not disputing that it is techincally correct to refer to the deceased as a pedestrian, but this

That's why he said misleading rather than an outright lie. He is not disputing that it is techincally correct to refer to the deceased as a pedestrian, but this scenario (someone out of their car on a freeway) is not what is going to spring to the mind of someone just reading the headline.