The Washington Post published a false headline that Michael was the first Category 5 since 1992 earlier today. They have since corrected the headline to include "to make landfall", which is still false, but with fewer counterexamples.
In particular, though, what would be correct is "to make landfall in the US", but even if that was intention, the headline as such implies a false insignificance of category 5 landfalls in other countries like Mexico.