On Saying the Name of a Movie, in the Movie

So last night I watched the movie American History X (1998). For those of you that haven't seen it, the film is about a Neo-Nazi (played by Edward Norton) who gains perspective in prison and tries to steer his younger brother from going down the same path once he gets out. I enjoyed it, but about 10 minutes in a character dramatically says the title of the movie. While I didn't particularly like how it was done in this film, I'm still unsure as to how I generally feel about when this happens.


(my apologies for the poor quality, but the point remains)

I've seen the 'title of a movie dropped in dialogue' done very well. For example, I enjoyed how the drug dealer Cheese in one of my favorite movies of all time Gone, Baby Gone (2007) was the one to say the title. Also, I loved how Robert Downey, Jr. said "I am Ironman." at the end of Ironman (2008). I think a lot of this rests on the screenplay writer's ability to select a title.

1.) Do they think of a title and then write the screenplay? I think this was the case in Ironman.

2.) Do they think of a title and then try to incorporate (force) it into the dialogue of the screenplay? This is clearly what happened with Clear and Present Danger (1994). The phrase comes from a famous Supreme Court case concering free speech.

Or

3.) Do they write a screenplay and then go back and select the title from a line of dialogue? I think this was the case with As Good As it Gets (1997).