Sure, there might be, there might not be, but regardless this article doesn't even suggest at the possibility of something like that going on. If this was a story about Snowden's hinting at it, sure, the title makes sense. If this article discussed the FBI's targeting efforts as being racially motivated, the title makes sense. But this is an article about the Memphis PD.
The title is a dishonest representation of the content of the article. That's what I take issue with. Nothing more, nothing less.