NewsBusters give a bit of history on this:

Fox & Friends invited me on air today to discuss how The Washington Post could run a small obituary on left-wing domestic terrorist Dwight Armstrong and describe in the headline only as a “Vietnam War protester.”…

Every other newspaper obit I found had the B-word (“bombing” or “bomber”) in the headline. In the New York Times, Margalit Fox had a strong opening:

Dwight Armstrong, one of four young men who in 1970 bombed a building on the University of Wisconsin campus in Madison, killing one person and injuring several others — a political protest that, gone violently wrong, endures in the national memory as an act of domestic terrorism — died on June 20 in Madison….