Yeah, I'd agree that most are synthesized. But I do frequently see headnotes that are verbatim or nearly verbatim slices from the text. Just grabbing a case at random: Kearney v. Salomon Smith Barney, Inc., 39 Cal.4th 95 (2006). The 4th headnote reads:
> The federal system contemplates that individual states may adopt distinct policies to protect their own residents and generally may apply those policies to businesses that choose to conduct business within that state.
And the opinion reads:
> [T]he federal system contemplates that individual states may adopt distinct policies to protect their own residents and generally may apply those policies to businesses that choose to conduct business within that state.
