I have the following markup:
Title
Title
-
This is what the first-of-type and nth-of-type selectors are for.
For example:
.ctr-1 h3:first-of-type { display:none; }
/* - Or - */
.ctr-1 h3:nth-of-type(0) { display:none; }
This would hide the first h3 descendant of .ctr-1, regardless of its location inside the parent element.
Granted, in your specific example, the h3 is indeed also the immediate (>) and first (:first-child) descendant of .ctr-1 . But if this is a coincidence, you might not be able rely on it. In that case, nth-of-type is the way to go.