Go look up "fair use" under copyright laws.
Person *et al*(2023). "The Unbearable Lightness of Tardigades", *Little Creatures*, 27, 100-110
Then even though the title is really clever and creative copying it into my citation list is still fair use.EDIT: I guess you could argue that the absence or presence of a citation is a factor in the character of the use or the use's effect on the market value of the original with a straight face but it's very, very much not going to be either necessary or sufficient for either of those tests.