I freeze framed the article article that appears about GOB's escape from the prison, and the actual text of the article talks about the opening statements from a murder trial of a Bluth who who stabbed his wife to death. Kind of an odd thing for an easter egg, huh?
I did a bit of researching online and couldn't find any real-world news reports of that happening. This episode aired in 2003 and a lot of smaller news publishers weren't digitally distributing their news yet.
I find it hard to believe that this is actually a reference that Michael killed Tracey. It'd be way out of character for him. But you never know!