Wikipedia:Articles for deletion/Enrique Moreno

From Wikipedia, the free encyclopedia

The following discussion is an archived debate of the proposed deletion of the article below. Please do not modify it. Subsequent comments should be made on the appropriate discussion page (such as the article's talk page or in a deletion review). No further edits should be made to this page.

The result was general confusion because it's difficult to figure out to what article(s) the individual comments apply, but at any rate no consensus to delete all of these articles. Any renominations should be made individually, if a merger to the article about the nomination issue fails to find consensus.  Sandstein  19:44, 30 May 2008 (UTC)

[edit] Enrique Moreno

Enrique Moreno (edit|talk|history|links|watch|logs) (delete) – (View log)
  • Note to closing admin: There are multiple "keeps" and "speedy keeps" in this article that originate from two editors. I am partly to blame for this confusion because I added other articles to this afd after it had already begun. In any case, please note each !voter when figuring out the concensus. Thank you. --brewcrewer (yada, yada) 21:54, 25 May 2008 (UTC)

A bio about an unnotable person that was a pawn in a notable event. This lawyer failed a judicial nomination because of Republican-Democrat politics. This political issue is notable, and there should be an article about this event. However, there should not be a seperate bio for each person that was a pawn in this event. He was one of seventeen lawyers whose nomination falied for this reason. He was not notable before this event, and this one-time event (i.e. WP:BLP1E) should not cause him to meet the notability standard of WP:BIO.

An afd (link) of one of the aforementioned "17" resulted in a keep, but that person is very different. He was notable prior to the failed judicial nomination. He was Governer Gray Davis's secretary of legal affairs and he was a judge in the Calofornia judiciary syetem. This person was not notable prior to the failed nomination, and his failed nomination shouldn't make him notable. brewcrewer (yada, yada) 05:21, 25 May 2008 (UTC)

Christine Arguello (edit|talk|history|links|watch|logs)
Robert Raymar (edit|talk|history|links|watch|logs)
Allen Snyder (lawyer) (edit|talk|history|links|watch|logs)
Charles "Bud" Stack (edit|talk|history|links|watch|logs)
  • Keep. I am the article's creator. This article should remain for five reasons: 1) A lawyer who was nominated to a court one level below the U.S. Supreme Court meets the notability threshold; 2) A lawyer whose (ultimately unsuccessful) nomination then becomes part of not only an open fight between two parties in the U.S. Senate but also has his name invoked by both the sitting president and the sitting vice president (and presidential candidate) at the time meets the notability threshold; 3) Federal judicial appeals-court nominations have become increasingly controversial, and Moreno is relevant because his name continually has been raised in speeches all throughout this decade by U.S. Sens. Pat Leahy and Dianne Feinstein as one of 17 non-acted-on nominations in the latter part of Clinton's presidency; 4) Given his still-young age, it's reasonable to think that Moreno may well be renominated to a Fifth Circuit by a future Democratic president; and 5) A Google News search for "Enrique Moreno" and "judge" produces 125 results, so there is some notability there. I don't think this is a BLP1E case at all. As a user said in the previous AFD article referenced above (the article about Barry Goode), "When the "one event" you're known for (assuming that's true) is a major political tussle in the upper house of a national legislature, your notability is not really in question. WP:ONEEVENT was intended for people who get 15 minutes of fame for balancing a hot dog on their nose and the like." —Preceding unsigned comment added by Jarvishunt (talk • contribs) 06:25, 25 May 2008 (UTC)
  • I will respond to each of your points in turn:
  1. There are over a hundred judges at that level. Being nominated to that level doesn't establish notability.
  2. Being mentionened by the President doesn't move him beyond WP:BLP1E. --brewcrewer (yada, yada) 06:49, 25 May 2008 (UTC)
  3. Is an excllent argument for the creation of an article about this controversy, not about each person that was a pawn in this political fight.
  4. Is violative of WP:CRYSTAL. Any future nominations can be dealt with when he his actually nominated.
  5. The ghits all link to the one event. Your understanding of WP:ONEEVENT is - with my utmost respect - incorrect. Balancing hotdogs on noses and judicial nominations are the same for WP:ONEEVENT purposes. We don't decide the societal importance of people. We only look to see if that person has recieved significant coverage outside of one-time events.

---brewcrewer (yada, yada) 06:52, 25 May 2008 (UTC)

  • Comment The argument that Moreno and the other judges are non notable is really outside precedent. Take the example of Wikipedia:Articles for deletion/Megan Marshak. That is an ex-presidential aide, who happened to be in bed with Vice President when he died. There are zero biographical details beyond the one event. Putting up all of these judges would be tantamount to WP:PTEST. MrPrada (talk) 20:23, 25 May 2008 (UTC)
  • Delete Non notable person. Fails WP:N. Undeath (talk) 07:50, 25 May 2008 (UTC)
    Comment. One familiar with the subject matter cannot read the articles as they are now and come away with that assessment. On individual merit alone, each has inherent and demonstrated notability verified by second party sources, and easily meeting WP:BIO. MrPrada (talk) 20:23, 25 May 2008 (UTC)
  • Keep. Prominent jurist. Sources abound, 125+ nontrivial second party on the judgeship alone. Perhaps someone should create a bot to do ghits for AfDs. No, I am not suggesting we keep per WP:GHITS, but I do think there is notability outside of 1E. MrPrada (talk) 08:24, 25 May 2008 (UTC)
  • Prada: None of the ghits that you provide show notability outside of the one event (the unsuccessful nomination). --brewcrewer (yada, yada) 08:55, 25 May 2008 (UTC)
  • I think you're making too strict a ruling on BLP1E, and here's why. To me, "one event" would be the nomination failing. Or being filibustered. Or him being nominated to begin with. Not taking all three together over a period of 1999 to 20001. Most of those 125 that I listed (and there are more) are from major publications, and include plenty of biographical data to flesh out the rest of his life beyond the context of one event. Therefor, not only do they demonstrate notability for a series of events (rather then BLP1E), they also provide notability for his earlier career. Furthermore, there are several in there which take place after the nomination, and showed up because I used "Enrique Moreno Judge" in the search string, and they make reference to the failed nomination while discussing another topic, a key indicator that he has lasting notability. MrPrada (talk) 14:27, 25 May 2008 (UTC)
  • Prada: Your defintion of BLP1E would preclude its applicability in the most classic of BLP1E situations. Take for example Sean Bell, now a redirect to Sean Bell case. Google him and you get - yes - nine million - hits. As many ghtis as he gets, they all stem from one event. Yet, if you apply your argument to Sean Bell, BlP1E doesn't apply to that case either. You can divide that one event into multiple events. 1 - the incident, 2 - the officers' indictment, 3 - the trial, 4 - the acquittal, 5 - the subsequent protests, 6 - the (soon to be) civil lawsuit. Therefore, even if one event stretches out for a few years, that doesn't mean that the event is outside the realm of WPBLP1E. --brewcrewer (yada, yada) 16:01, 25 May 2008 (UTC)
  • You are partially correct on both points, but still do not prevent a convincing reason to delete his biography. From a notability standpoint, Sean Bell, like Scott Thomas Beauchamp, was not notable outside of the 1E that created a controversy. Moreno seems to be. From the 1E standpoint, there are many instances from tragedies to battles that receive a single article. Would each judge's nomination therefor get its own article outside of the biography? No. The sensible place would be in a biography of the judicial candidate. In this particular instance, you have a judge who is nominated, and returned by the Senate (1E), and then renominated (another event), as I stated above. These seperate events are not all connected to one event on one day, like a tragedy or a battle. Arguing otherwise is a stretch. There is no need, reason, or policy to support deletion here. The follow on stories that have mentioned Moreno recently confirm that he meets WP:NTEMP for more then just the confirmation. Nothing can be clearer then BLP1E itself: If reliable sources only cover the person in the context of a particular event, then a separate biography is unlikely to be warranted Sean Bell, and Scott Thomas, are chronicled in relation to the event that made them notable. We read little about who they are, where they come from, etc. On the other hand, Moreno receives a wider breath of coverage in the articles about his confirmation, indicating coverage beyond the context of the nomination itself, and warranting a seperate biography. MrPrada (talk) 16:18, 25 May 2008 (UTC)
  • Comment. I'd say that Prada's comments capture exactly why the fight over Clinton judicial nominations weren't a onetime event and as a result shouldn't be classified or viewed as such. It really was a series of fights that took place over a more than five-year period, involving many different players at many different times, with vastly different outcomes. I'd argue that each one was an individual event. Some other thoughts on the comments raised so far:
  1. There are indeed over 100 appellate level judges, but these are lifetime appointments. In a given year, a president nominates 5 to 10 of these at most. Nomination *is* a huge deal--there aren't hundreds and hundreds of them a year (or even in an eight-year presidency).
  2. I should have elaborated on the president mentioning one's name. It's true that if the president congratulates Podunk High School for winning the state spelling bee, that doesn't establish notability. But, when the mention by the president (and the VP, who's also the presidential candidate) is part of a Senate fight over his nomination, the notability has standard has been met, in my opinion.
  3. Brewcrewer makes a fine point about WP:CRYSTAL, and I withdraw that argument.
  4. Moreno has more notability than just the judicial nomination. I'll add that shortly.User:Jarvishunt —Preceding unsigned comment added by 76.223.78.206 (talk) 15:33, 25 May 2008 (UTC)
  • Christine Arguello: Former Deputy AG of Colorado, amongst other things. Keep. MrPrada (talk) 20:28, 25 May 2008 (UTC)
  • Speedy Keep Christine Arguello. She's Colorado's former Deputy Attorney General, she was nominated to the Tenth Circuit in 2000, and she's now expected to be nominated to a U.S. District Court seat by President Bush any day now (see this article here from May 17: http://cbs4denver.com/local/Judgeships.white.house.2.726486.html). Arguello meets the notability standard by a lot. This isn't a case of WP:CRYSTAL (or B; this is breaking news that's happened in the last week. Jarvishunt (talk)
  • Robert Raymar: Former Deputy AG of New Jersey, amongst other things. Keep. MrPrada (talk) 20:28, 25 May 2008 (UTC)
  • Speedy Keep of Robert Raymar. He's the former Deputy Attorney General for New Jersey. —Preceding unsigned comment added by Jarvishunt (talk • contribs)
  • From the article: "During Bill Clinton's presidency, Snyder represented Deputy White House Counsel Bruce Lindsey during the Whitewater controversy. In addition, Snyder represented actress Elizabeth Taylor, successfully blocking an ABC-TV docudrama about her life, according to a September 2004 article about Hogan & Hartson in the Washingtonian magazine. And, Snyder represented Netscape as its chief corporate attorney during its antitrust fight against Microsoft." And this followed by the information about the nomination. Recommend speedy keep of Allen Snyder (lawyer). MrPrada (talk) 20:28, 25 May 2008 (UTC)
  • Speedy Keep of Allen Snyder. In addition to his failed nomination to the D.C. Circuit (which easily is the single most powerful court in the U.S. after the Supreme Court--it's more powerful than even the other appellate courts), Snyder represented Elizabeth Taylor in her litigation against ABC-TV re: a docudrama of her life, he was a figure in the Whitewater controversy by representing Bruce Lindsey, and he represented Netscape in its litigation against Microsoft. Snyder is not a WPBLP1E case at all. Jarvishunt (talk)
  • Charles "Bud" Stack : Subject of four seperate NYT articles, just in its current WP form. I'm sure there is much more to tell. Keep. MrPrada (talk) 20:28, 25 May 2008 (UTC)
  • Comment. Almost any judicial nominee to an appellate court or nominee for a cabinet post has some inherent notability, stemming from their nomination. The five failed judges in question have all had storied careers as jurists, litigators, professors, etc., I cannot see how we would delete as non notable. MrPrada (talk) 20:18, 25 May 2008 (UTC)
  • Update. I added more on Moreno's professional career, including some news accounts on large judgments that he has won that give more credence to his notability. Jarvishunt (talk)
  • Speedy keep of Charles "Bud" Stack. When you raise $7 million for the Democratic party and get nominated to a Circuit Court of Appeals seat and appear in a multitude of New York Times articles, there's really no further question about your notability. —Preceding unsigned comment added by Jarvishunt (talk • contribs) 20:38, 25 May 2008 (UTC)
  • Keep The article asserts notability in its opening sentence. WPBLP1E has no bearing on this, and it seems rather sweeping to assert that these legal people have no other claim to notability. Clinton didn't pick random passers-by as nominees. -- roundhouse0 (talk) 20:42, 25 May 2008 (UTC)
  • Note: This debate has been included in the list of United States of America-related deletion discussions. —MrPrada (talk) 20:42, 25 May 2008 (UTC)
  • Note: This debate has been included in the list of Law-related deletion discussions. —MrPrada (talk) 20:42, 25 May 2008 (UTC)
  • Note: This debate has been included in the list of Politics-related deletion discussions. —MrPrada (talk) 20:42, 25 May 2008 (UTC)
Relisted to generate a more thorough discussion so that consensus may be reached.
Please add new comments below this notice. Thanks, MrPrada (talk) 20:42, 25 May 2008 (UTC)
  • Note: This debate has been included in the list of Law-related deletion discussions. -- Fabrictramp | talk to me 20:45, 25 May 2008 (UTC)
  • Keep There appears to be a good faith effort underway to improve the article, and the discussion has morphed into discussion of multiple merge and delete suggestions. Let the dust settle and re-nominate if the article's issues can't be solved outside the AfD process. Townlake (talk) 21:14, 25 May 2008 (UTC)
  • No basis for meeting the notability standard of WP:BIO was given. --brewcrewer (yada, yada) 22:44, 25 May 2008 (UTC)
    • We'll have to agree to disagree then, because no basis for not meeting the standard of WP:BIO has or can be given. :) MrPrada (talk) 23:39, 25 May 2008 (UTC)
      • The burden is on those claiming notability to establish notability. We all know you can't expect someone who claims that something doesn't exist to prove that it doesn't exist. --brewcrewer (yada, yada) 00:52, 26 May 2008 (UTC)
        • I disagree. Discussions default to keep, not to delete. There is plenty provided above which would establish notability. The burden is on you to refute it. Thus far, you've claimed that the sources provided only covered one event (which I showed to be incorrect), that they only were trivial (ditto), etc., so the keeps have done their due diligence.MrPrada (talk) 04:18, 26 May 2008 (UTC)
          • The fact that the initial burden falls on the creator of the article has nothing to do with default to keep after the discussion. For the simple fact that you cannot expect or request someone to prove that something isn't. Therefore, just stating that it's notable and then requesting that it be refuted makes absolutly no sense. And a !vote that says its just notable without backing it up is - with all due respect - valueless. You, Prada, have obviously attempted to back up the notability, and therefore you have to be reckoned with. But my initial point above was that "good faith effort underway to improve the article" is not a basis for notability and non-deletion, and it doesn't even meet the discussion threshold. --brewcrewer (yada, yada) 05:18, 26 May 2008 (UTC)
  • Delete.Well, sadly good faith is not enough to keep an article from being deleted. This man has not done anything notable enough to be on Wikipedia. It almost seems like the creator of the article is Ernique(just saying). Basically, the man is no-notable.Gears Of War 21:43, 25 May 2008 (UTC)
  • A presidential nomination/appointment is a big deal, especially to the second highest court of the land, the United States court of appeals, each district of which is responsible for 4-5 states and has only a dozen judges more or less. WP:HOLE is an unacceptable reason to delete. This is an encyclopedia. MrPrada (talk) 21:51, 25 May 2008 (UTC)
  • Ha funny. What is he doing now then? And secondly apparently I my comments are not the only ones who want this article deleted, so that means something is wrong. I am also not the last person to say this guy was non-notable. Sadly he did not play a big a part as you make it put to be.Gears Of War 21:57, 25 May 2008 (UTC)
  • Gears of War, look under Moreno's professional career--since the failed nomination, he's been a lead (or sole) attorney on legal teams that won two very high-profile class-action lawsuits (see references). That's notability entirely apart from the nomination to the Fifth Circuit. Jarvishunt (talk)
Sadly no matter what you try to show me, I just think that the article should be delted, and thats never gonna change, Gears out.Gears Of War 22:07, 25 May 2008 (UTC)
  • Thus far, there have been no explanations to "non notable", tantamount to WP:ATA—WP:IDONTKNOWIT, which makes me incredulous. Also, for someone seeking to become an administrator forming a consensus is based on evaluation the arguments of others and coming to an agreement, so perhaps you should look at what he's trying to show you, you may change your mind after all. MrPrada (talk) 22:09, 25 May 2008 (UTC)
  • Ha! You guys crack me up. Going into my own personal conversations to try to change my mind. I have considered his case and I dont appreciate you going into my personal conversations and trying to piss me off. I know what I said and I listened to all of your pleads. The dude is non-notable. And yet when some else said he was non-notable, no one jumped on him like this! But sadly that always happens to me. I will not change my mind, and if the article is so good, it will be saved after all.Gears Of War 22:18, 25 May 2008 (UTC)
  • I think Gears gave a coherent and valid reasone for deletion - "This man has not done anything notable enough to be on Wikipedia." A long explanation filled with alphabetical abbreviations isn't required to state an opinion around here.--brewcrewer (yada, yada) 22:22, 25 May 2008 (UTC)
    • Much like just a policy or guideline, simply stating that the subject of an article is not notable does not provide reasoning as to why the subject may not be notable. Actually, my comment on forming consensus was in response to "Sadly no matter what you try to show me ..." which followed Jarvishunt's asserstion of notability to Gears. I have addressed each editor that has stated an nn-concern in a similar manner, so I apologie to Gears if he feels that he was jumped on. However, I would be doing him as much of a disservice by not pointing out the spirit of consensus (which is what has lead me to his talk page, wehre I am currently typing a response) as he would be by choosing not to evaluate Jarvhishunt's arguments. MrPrada (talk) 22:29, 25 May 2008 (UTC)
  • Then delete my two cent, so be it They think I am just being ignorant basically take away my reasoning.Gears Of War 22:23, 25 May 2008 (UTC)
  • I was neither asking you to change your opinion nor consider anything contrary to your opinion, nor did I imply we discount it. I merely suggested an exercise in consensus building after you mentioned "It doesnt matter what you show me ", which would be to at least evaluate the information. Its completely optional. MrPrada (talk) 22:34, 25 May 2008 (UTC)
  • For the sake of Peter dude, the reason I said that was to say that no matter how much he argued with me I had made my decision and would not change my mind.Gears Of War 22:36, 25 May 2008 (UTC)
    • I don't think Gears can be blamed for stating he will not change his mind. This page has pretty much hashed out all the possible arguments, pro and con. If Gears has read the applicable articles and analyzed both arguments on both sides, he shouldn't be jumped on to change his mind, and be accused on being a non-consensus-builder. Indeed, if any side isn't working towards a consensus its the keep side. After nominating the articles for deletion, I felt that it would be a fair compromise to merge into President Clinton's judicial appointments controversy instead of deleting. Yet, the keep side isn't budging. They want a full bio on each and every person that ever went through an unsuccessful attempt to become a federal judge. --brewcrewer (yada, yada) 05:32, 26 May 2008 (UTC)
      • I would surmise that the controversy certainly does deserve its own article, much like the Bush administration judges Priscilla Owen, Miguel Estrada, etc. However, at least in the case of these five (and most of the others that I read articles on today), in my opinion there is sufficient notability to warrant inclusion. As daughter articles they would only compliment the main controversy article, which in time could well become a featured topic. The fact that it is the Circuit Court of Appeals, the second highest court in the U.S., is really what seals the deal for me with regard to keeping the biographies. Is Joseph H. Boardman notable outside of being Chief of the Federal Railroad Administration? Or Raymond P. Martinez beyond being Deputy Chief of Protocl for the State Department? Possibly. And I submit it is likely that they would retain that notability, even if their nomations to their respective positions (which have gauranteed them inclusion) had failed, they would still warrant a biography. The Circuit Court of Appeals is no different then any other high level administration appointment. And appointees are in many ways non-elected politicians. Its possible for an unsuccesful candidate for election to fail WP:POL and meet WP:BIO, so why not an unsuccesful candidate nominated by the President? At least with these five, I believe they do exceed the standard. As Brew has pointed out, I think its been hashed out enough at this point, so I will leave it to other editors to evaluate whats been stated here. MrPrada (talk) 06:04, 26 May 2008 (UTC)
        • There seems to be a defacto acceptance that any high govermental official is basically automatically notable. Joseph H. Boardman and Raymond P. Martinez might not pass the WP:BIO standards, but an afd of their bios is guarenteed to fail. Similarly, when it comes to baseball players. A person who played three games of professional baseball in 1998 is considered notable, and an afd of his bio would fail, notwithstanding the failure of establishing WP:BIO. But the Wikipedia community has only applied these bright-line rules to people that have actually made it. If you have a high-level govement job you are notable, but if you never got any high-level job, you must meet the regular notability standards of WP:BIO and you must move beyond WP:BLP1E. This much I do agree, that it is time for other editors to chime in. --brewcrewer (yada, yada) 06:50, 26 May 2008 (UTC)
  • I like the idea of merging the page also. Every single person does not need their article unless the President Clinton's judicial appointments controversy page has been tagged with a long tag and is being split into different articles. Other than that every page will either be merged or deleted because every person on their own is not notable, but an article with all of those men in one is an awesome idea(depending on how well the article is written also)Gears Of War 12:59, 26 May 2008 (UTC)
  • Comment. In thinking more about my case for why Moreno, Raymer, Arguello, Snyder and Stack all are sufficiently notable to merit individual Wikipedia biographies, I think it's helpful to look at the issue from another direction, regarding the case of Miguel Estrada.

Like the above five, Estrada was nominated to a federal appeals court judgeship by a president, and like those five, Estrada never was confirmed. (Estrada withdrew his nomination, as did Stack.) Estrada's contributions to notability outside of the failed circuit court nomination are roughly on par with those of Moreno, Raymar, Arguello, Snyder and Stack--certainly not more than the non-nomination contributions of those five, but also not appreciably less (Estrada was an assistant to the solicitor general for a time, while Moreno won some huge financial judgments for his clients in notable cases and also was the subject of comments by both Clinton and Gore in the 2000 race; Raymar was NJ's deputy attorney general at one time; Arguello is on the verge of being nominated to a U.S. district court and has received wholly separated news-media coverage for that, eight years after her nomination failed; Snyder has represented some major clients and was a figure in the Whitewater controversy; and Stack has been a major fundraiser and was a 1996 presidential campaign issue).

However, I don't think there's anyone who would argue that Estrada isn't notable enough to rate a Wikipedia biography. Have there been more news articles about Estrada than those five? Probably (although the vast, vast majority of those articles would deal with Estrada's failed nomination). Was Estrada's nomination during a period of somewhat greater news media coverage of opposition to certain judicial nominations because of the specter of the Senate filibuster? No doubt about it. But it's pretty clear that Estrada's underlying situation and non-nomination notability are very similar to those of Moreno, Raymar, Arguello, Snyder and Stack. As Estrada's biography has no business being deleted--he's obviously an individual whose notability isn't in question--so too should the biographies of Moreno, Raymar, Arguello, Snyder and Stack remain. Jarvishunt (talk) —Preceding comment was added at 05:09, 28 May 2008 (UTC)

  • Delete, does not appear to be notable (yet). Stifle (talk) 08:57, 28 May 2008 (UTC)
  • Keep at least Stack, Arguello, and Moreno owing to the multiple independent and reliable sources and reasonable state of the articles. — brighterorange (talk) 12:52, 28 May 2008 (UTC)


The above discussion is preserved as an archive of the debate. Please do not modify it. Subsequent comments should be made on the appropriate discussion page (such as the article's talk page or in a deletion review). No further edits should be made to this page.