Accusations of bias aside, we'd likely agree that the active voice is more interesting and concise here:
- The seventh game was won by the Red Sox.
- The Red Sox won the seventh game.
But what about headlines, in particular those on the Web? The advice from usability expert Jakob Nielsen is to consider passive voice. Putting the key words at the start of a headline, Nielsen says, can be more important than making the headline active. Doing so helps people who scan the results of a Web search find what they are looking for. Nielsen suggests sometimes using the passive voice in blurbs, leads and lists as well.
Nielsen's perspective is not new or unique to the Web. My colleague Bill Cloud says that during his work at The Miami Herald, he would sometimes write headlines and blurbs in the passive voice to allow the important words to come first. This was not Herald policy and didn't have the eye-tracking research behind it that Nielsen has, but it was a widely accepted practice.