OK, getting more information ... I think the issue here is this is for a blog and I'm thinking the Title tag usurps the H1.
For a blog, it would be:
<title>Awesome Cool Headline<title></p> <p><H1>Awesome Cool Headline<H1></p> <p>which would look redundant. So I think I could use the first subhead as an H1 if it was written in a way that was relevant to the story, but I'm guessing best practices are H2. Although if I did that, I'd NEVER have an H1 on my pages unless I was doing a landing page promotion of some sort ... hmmm.</p></title>