Fairness in the fourth paragraph

Shouldn't fairness always be the lead? Instead, McCNN stretches for a false equivalence under the headline "Biden not holding press conferences, either". Four paragraphs in, Alexander Marquardt gets around to this:

To be fair, the famously talkative Biden has given 89 national and local interviews, according to the campaign. Palin, in contrast, has granted just a handful, including one to People Magazine.

After that, Marquardt is, incredibly, back to slamming Biden for "lack of access."