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This is a good question and I can see where your confusion is. If the title of work is not capitalized, then you should not capitalize it in your summary. The author's intentions should be honored in this situation.
With this stated, there should be little problem with this rule, because the title of works (like articles in newspapers and journals) are put in quotation marks anyway. Hence, when you are writing the summary of the article, the reader will know that you are referring to an article by the quotation marks. In addition, the reader will know that the title of the newspaper article was left intentionally in small caps by the author, because of the quotation marks.
When it comes to the bibliography, you will put the newspaper in italics and the first letter will be capitalized.
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