Talk:Tort Reform/Archive 1

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Please add new archivals to Talk:Tort reform/Archive02. (See Wikipedia:How to archive a talk page.) Thank you. FRCP11 15:30, 17 October 2005 (UTC)

Contents

I see the light

Reading through the contentious exchanges below, I finally realized what has kept gnawing at me: This article is not a collaborative effort to inform some unspecified and unidentified audience about tort reform. Indeed, the audience is the "forgotten man" in all this ruckus. This article is just one more arena for carrying on the tort reform debate. I am all for engaging in that debate, but not in the guise of a collaborative effort at consensus. Adios, amigos. PPE 01:30, 16 October 2005 (UTC)

PPE critique

Back to the drawing board. I agree with Larrabee that this article is structurally flawed to the point that the current structure should be abandoned and a new structure — and new content — be adopted.

For example, from paragraph 2:

the commonly understood usage of the term [tort reform] in the political and academic arena is to describe a movement that would reduce the amount of tort litigation or damages.

Having written on tort reform for more than 10 years, I know that this characterization is inaccurate and simplistic on several points:

1) Although some who advocate tort reform consider themselves to be part of a "movement," it is by no means the case that all do.

2) You attribute to this movement the central objective of reducing the "amount of tort litigation and damages." Again, this is mistaken. People who advocate tort reform advocate an enormous variety of reforms across a range of legal issues; it is not accurate to suggest that all reform efforts across all these issues aim at one overall objective of reducing the "amount of tort litigation and damages."

3) To say that tort reform "does not include measures that expand liability, such as laws that create new causes of action" is simply not accurate.

I could go on for several thousand words citing errors of one kind or another in this article. But enough. Let me suggest a fresh approach to this very complex subject:

You might begin by noting a definition that is not controversial: A tort is a civil (as disinguished from criminal) wrong committed against a person or property. Thus the law of torts spans the full range of human interaction, because in any facet of life, civil wrongs can and do occur: Defective products harm people; breached contracts harm people; negligent behavior (such as drunk driving or medical malpractice) harms people; dishonest behavior (fraud of all kinds) harms people.

Over centuries, a huge body of common and statutory law, including procedural rules, has been created to redress these wrongs. Not surprisingly, this body of law touches on many controversial questions. To give just one example: Suppose A serves liquor to B, who then drives while intoxicated and injures C. Who is liable for C's injuries: A alone? B alone? Both A and B?

Reasonable people can and do disagree on such questions, and there are literally thousands of them connected with tort law. Some people believe that some answers given by courts and legislatures could be improved; such proposed improvements all come under the head of "tort reform."

At this point, it would probably help readers if you followed Larrabee's advice and adopted a pro/con format covering a modest range of issues in layman-friendly terms. By that I mean: Give concrete examples first, and then use those to introduce legal terminology that is the subject of debate about tort reform.

I think this article as currently written is too ambitious in trying to cover such a vast territory. It would be more helpful to readers, I think, to pare down the number of issues you tackle and just clearly illustrate a few of the more fundamental ones.

First of all, what motivates some people to advocate tort reforms? Begin with one or two of the most salient reasons. For example, a Texas judge recently uncovered evidence of massive fraud in silicosis lawsuits: Thousands of plaintiffs were certified as sick by a dozen doctors who had never seen the patients, never taken a history, not done any lab work, had barely glanced at a chest X-ray, and couldn't describe the clinical criteria for diagnosing silicosis. Those are all facts established in court, and they prompted many people to call for refoms: procedural safeguards that would prevent unscrupulous lawyers and plaintiffs from filing such fraudulent claims.

You could take this approach across several areas: contracts, med-mal, class actions, product liability .... and just illustrate the controversy in each case by describing what reformers propose, why they propose it, and why their opponents disagree.

You are also well-advised not to use scare quotes as follows:

Opponents of "tort reform" contend that "tort reformers" exaggerate the costs and ignore the benefits of the current tort system.[6] For example, opponents of "tort reform" contend that ....

When you put scare quotes around "tort reform," you aren't taking a NPOV. People who advocate tort reforms never use scare quotes; their opponents do that to show their disdain for reform proposals.

For these and several hundred other reasons I won't go into, the current structure and content are too flawed to repair. My advice is to toss this article and begin anew.

- PPE

PPE: the rule on Wikipedia is to cite sources. Please provide a single example of a mainstream press account using "tort reform" to describe "measures that expand liability, such as laws that create new causes of action." I've never seen it done. The definition that's in this article corresponds to what's in Black's Law Dictionary. See also other web definitions.[1]
The place to define "tort" is in the tort article, not this one. It's not the place of this article to "introduce legal terminology that is the subject of debate about tort reform." If you're stating that individual terms are at too high a level for lay comprehension, that's an argument to wikify those individual terms, rather than to dumb down this article. I'll keep an eye out for such terminology, but perhaps you can make a specific suggestion rather than refer to "hundreds" of problems? Perhaps you didn't intend it as such, but it comes across as condescending.
I agree that the scare quotes don't belong. I'll take them out now.
The absence of concrete examples reflects complaints about citations to specific cases; any time a particular case was mentioned, arguments about how much detail should be added ended up burying the flow of the article in a morass of irrelevant detail. But there should be a reference to the silicosis scandal. Perhaps you could write that article and we can link to it from this one?
The New York Times ran a 3,000-word feature on Oct. 9 that gave a very good overview of the silicosis scandal. PPE 23:21, 15 October 2005 (UTC)
Thanks. I'm familiar with the silicosis scandal, since I've been writing about it since 2003. The question is one of finding the time to write a Wikipedia article about it. I'll do it eventually if no one else does.-- FRCP11 00:18, 16 October 2005 (UTC)
I think you misunderstand Whitfield's suggestion of pro-con. He wanted all the pro arguments in one place, and all the con arguments in another. That would be unreadable.
I agree that the article attempts to tackle too many issues. A solution would be to create some sub-articles that can address issues in more detail. It's something I'll tackle over the next few weeks. -- FRCP11 03:14, 15 October 2005 (UTC)
PPE, if you think we should toss the article and begin anew, I'd suggest you proceed as follows: Create a temporary version as a subpage of your user page (I'd set it up as something like User:PPE/Tort reform (temp) and if you like that title you can just click on it to start); copy the entire existing article into the new temp page you've thus created; then go to work editing it as you see fit. When it reflects your thoughts at least roughly, post an explanation here of why you did what you did, and invite others to edit it, or to discuss it on its talk page. There might develop a consensus that the current article should be replaced by a temp version that's been edited by others. If your suggestion doesn't attract support, it's a lot easier to deal with than if you make wholesale changes to the main article, which others then come along and revert, to the accompaniment of nasty comments all around. (I speak from experience here.)
As for the definition of "tort", we can't get into detail here, but we should give the lay reader some rough idea of what's covered. The classic definition I learned was "a civil wrong not founded on contract". One could haggle over the definition, but, whatever wording is chosen, it's worth devoting a line to make clear that this article doesn't concern criminal cases and doesn't concern contract litigation. JamesMLane 06:45, 15 October 2005 (UTC)
I've made that change in the second paragraph, and in doing so, realized that tort reform is about more than just tort law; it bleeds into the law of contract when one is talking about things like arbitration clauses and liability waivers. -- FRCP11 10:43, 15 October 2005 (UTC)

Use of Specific Cases

I think it is unwise to list specific cases such as the Zimmerman and Price cases. Specific cases almost always involve complexities that can be argued in a variety of ways at great length. That is what trials are for. Necessarily, any examples lead to ommissions of key facts and skewing of claims in one direction or the other, even if unintentionally.

--Whitfield Larrabee 14:48, 23 September 2005 (UTC)

Given that the tort reform complaint is that trials are coming to the wrong results, the argument that a trial should be dispositive of the question seems specious. I don't see any evidence that Price or Zimmer were characterized incorrectly. In Zimmer, in particular, the jury found 1% liability, and joint and several liability law held the city guilty 100%, which is precisely the point. It's possible the joint and several liability debate should be moved to that article. -- FRCP11 15:24, 23 September 2005 (UTC)

There is a claim that Zimmer v. City of Milwaukee found this. I see no reference to this decision, whether this decision was upheld on appeal. There is no link. This claim is unsubstantiated except on the web sites of groups that have an agenda and have shown a willingness to distort facts. Based on the current state of referencing, I don't even know if there ever was such a case.

--Whitfield Larrabee 22:05, 26 September 2005 (UTC)

Are you disputing that a defendant held jointly and severally liable and 1% responsible will be assessed 100% of the damages? That's the entire point. There are several other famous examples if you don't like Zimmer; I found a better one, which I'll use. But there are millions of trial lawyers with an incentive to catch ATRA telling a lie, so I'd be surprised if ATRA told a lie and no one noticed; ATRA has every incentive to be especially careful so that it doesn't lose credibility. Your accusation is unmerited. I also note that you're projecting. Need I remind you that you were the one who unthinkingly copied an anti-tort-reform site's out-of-context misquotation of Graham that I had to clean up? -- FRCP11 01:06, 27 September 2005 (UTC)
Ad hominem attacks on another editor as being "unethical" and "unthinking" strike me as excessive in this context. --Whitfield Larrabee 01:00, 16 October 2005 (UTC)
True or false? You took a single sentence from a Graham study out of context, and falsely claimed that it opposed tort reform. That's not ad hominem; it's an accurate recitation of the facts. "Unthinking" is the most charitable interpretation of that; the alternative is that you were deliberately dishonest. I didn't use the term "unethical"--you did, and you have some nerve complaining about ad hominem attacks when you've blanketed this talk page with attacks on me. -- FRCP11 02:30, 16 October 2005 (UTC)

POV tag

As a staunch opponent of tort reform for many years, I am swallowing my pride and putting up a POV tag. The article is biased. It is full of facts, it is well-written, it appears fairly accurate, but it is not neutral. I think the points it makes are valid, and it hurts me to do this to a page that helps strike down many of the most common misconceptions about tort reform, but the page does very little to address the points made by proponents, and has a massive imbalance of evidence towards opposition. We need to work to solve this. Deltabeignet 02:51, 7 Apr 2005 (UTC)

My opinion is that it's questionable to post the NPOV tag when there's no reason to believe that anyone has been blocked from improving the article -- e.g., no changes have been reverted or eviscerated. Your comment is certainly preferable to the actions of people who slap on the tag with no discussion on the talk page at all, but the objection amounts to saying "there's some unspecified information that could be added to this article that would make tort reform look better". Well, true, and there's also lots of information that could be added that would make tort reform look worse. Right now the article gives a brief but fair summary of the contentions made on each side of the controversy. Yes, there's a bit more backup provided for one side, but it's hardly overwhelming. I can't see a "massive imbalance of evidence" when there's so little evidence offered on the anti-tort reform side.
Anyone who wants to improve the article by adding appropriate pro-tort reform information is free to do so. The only recent attempt to edit the article from a pro-tort reform POV was this edit, which removed an anti-tort reform link and substituted one favoring tort reform. I restored the deleted information but left in the pro-tort reform link that the anon had added.
I'm not removing the tag but I personally consider it unjustified. Given that you haven't proposed any specific edits to remedy the alleged nonneutrality, do you envision that the tag will remain in place indefinitely, in the hope that, sooner or later, some tort reform supporter will wander by and add more information? JamesMLane 17:36, 7 Apr 2005 (UTC)
All right, "massive imbalance" was overdoing things. I always start these kind of things off too forcefully. Sorry for not giving examples; I think I had a few, but I accidentally deleted my original post and put an abridged version up. Here's what I mean:
"The proposals advanced as "tort reform" generally do not address the issues of frivolous suits brought by businesses against competitors or against government regulation, nor do they include frivolous defenses raised in consumer actions."
As I said earlier, entirely true, but sometimes the placement of certain facts is POV in itself, and I believe this may be one. More than once I've put up facts in articles and had them reverted because they gave a POV effect.
"Republicans generally voice support for states' rights and say they oppose an excessive role for the federal government. Many of them, however, support federal "tort reform" legislation that would override state decisions in an area of law that has traditionally been left to each state."
See above- placement of facts, not the facts themselves. Also, that section uses "heavily", which is a dangerous word.
"...heavily disputed claim..."
This isn't too hard to see. "Heavily" is unnecessary; tort reform was in a poll I saw shown to be on the backburner of public opinion. It doesn't add much. That kind of thing isn't too hard to work with, but it's the underlying sense of the entire article that got me. One of the main reasons for this now seems to be a graphic one; the paragraph on advocacy doesn't start "Advocates say", whereas the opposition one starts "Detractors claim". This is irrelevant in the long run, but the first time I read through, the lack of clear separation tricked me. I wrestled with myself for a while, then, having blown things out of proportion in my mind, applied the tag. Anyway, regarding the quote, "controversial" is a little better. I'll change that.
So, in retrospect, the POV tag was going too far. I think the page may still need a bit of editing. My mental echo chamber convinced me that it was a nearly hopeless cause, but it's really more minor. I'll try tweaking the article a bit and I'll see what we get. I think this page has the potential to do great things. Deltabeignet 22:07, 7 Apr 2005 (UTC)

Price v. Philip Morris

In another objectionable section, the following quote appears:

"For example, in a case now on appeal, an Illinois judge awarded US$10.1 billion against Philip Morris over cigarette advertising on behalf of a class of plaintiffs that excluded those who had suffered physical injury for smoking. "

The problem with this statement is that it doesn't explain in any detail the basis for the lawsuit, why the plaintiff's contended that they were entitled to this award, or even why the judgment should not have awarded this amount. The use of misleading, vague, lacking in citation and one sided examples does not lend to a good article although it may make for a good editorial. It is interesting that the quoted section make no reference to the name of the case, the case citation, the date, etc, so we have no means by which to look into the matter to clarify the meaning of the example or to check whether it is true.

Although I have no objection to a balanced description of this case, if it even exists, in its current form I am just deleting this example.Whitfield Larrabee 03:26, 10 September 2005 (UTC)

Wikipedia does not approve of this kind of editing by intimidation. Our standard is, instead, that editors should cite sources. I've read some things about the Price case, and my understanding was that plaintiffs' theory of recovery didn't depend on physical injury, but that's completely different from saying that the class excluded those who'd suffered such injury. You should add a citation for, at least, that point, bearing in mind that a citation to an advocacy site like overlawyered.com must be carefully assessed. JamesMLane 22:15, 10 September 2005 (UTC)
I've taken it back out. -- FRCP11 14:08, 13 October 2005 (UTC)

POV check

Well, now I've gone and done it again. I still get this sense that the articles may need a bit of checking; it's certainly come a long way from the "heavily disputed by many" days. I've done some editing, but I feel that this tag fits the situation well. Umm... that's about it for now. Deltabeignet 01:40, 27 Apr 2005 (UTC)

After letting it settle and be edited a little more, I've removed the POV check. I think it's a reasonable article now. Deltabeignet 02:48, 10 Jun 2005 (UTC)

POV tag

I note that there is a claim in the article that federal reform efforts have been modified to permit the repeal of federal caps by state governments. There is then a link provided to a web site. The link does not substantiate this claim. There are also numberous links to web sites of CALA and ATRA. These to groups are clearly corporate front groups. With so many links to their web sites, it seems that someone wants to skew the article by having links to these groups more prominently featured than other groups opposed to the "tort reform" agenda. I note that when I posted a link in the reference section to an alternative viewpoint, it was deleted.

--Whitfield Larrabee 00:29, 20 September 2005 (UTC)

I just visited this page and it needs work. For example, this statement, For example, this statement from the article, "gun control supporters, frustrated with their inability to achieve success in Congress, adopted a strategy of attempting to bankrupt the handgun industry through lawsuits before the federal government passed a law in 2005 to give immunity to gun manufacturers in certain lawsuits." is a major violation. A. There is no citation to any authority for this outlandish claim. Although there were lawsuits brought against the industry by some plaintiff's, the quoted section suggest that gun control supporters are all engaged in some massive conspiracy. The weapons industry is quite profitable, especially during a war, and they are hardly at any risk of going bankrupt from a handful of lawsuits. Essentially, the quoted statement is just an unsubstantiated allegation and opinion of the editor. The editor has no way of knowing that "gun control supporters" feel frustrated. Accordingly, I am modifying this statement.Whitfield Larrabee 03:06, 10 September 2005 (UTC)

"Regulation through litigation" is a major objection to the current litigation system among tort reformers, and it goes beyond the gun-control issue, which was cited as an example. Litigation has been a prominent strategy of the Brady Center and other gun-control organizations. The "weapons industry" is a different animal than the "handgun industry." I've restored the text, and toned it down. FRCP11 20:10, 10 September 2005 (UTC)

Reverting Article To Former State

Today I made several revisions to the article, including providing a link to the Court decision cited as an example in the case, providing a link to a relevant article used as reference, providing counterbalancing views to view points presented in the article, and adding detailed information about the class action lawsuit cited in the article.

Obviously, providing links to the case which I didn't even cite is not point of view. Simply reverting the article to the way that the editor, FRCP11 liked it before, doesn't seem to be an appropriate remedy. It simply retains imbalances in the article that pre-existed the revision.

Whitfield Larrabee 19:09, 19 September 2005 (UTC)

You made several separate revisions that were disorganized, had several misspellings(e.g., "ciggarettes"), several style errors, and several uncited claims that are simply false. For example, it is not true that "all fifty states" bar the use of junk science, especially at the time John Edwards was trying his cerebral palsy cases. The Daubert discussion didn't belong in the paragraph about politics. Marbury v. Madison has nothing to do with the question of the balance between federal and state courts. You added a cite to an article that had nothing to do with the topic. Finally, the article already had a link to the Court decision in Price v. Philip Morris, and you simply deleted that one and added another one using the wrong style. I reverted rather than try to pick through the sloppy edits for the stuff that belonged. Try to control your rage when you're editing. FRCP11 22:10, 19 September 2005 (UTC)
It seems to be your contention that some states permitted "junk science." I am not familiar with any such state court ruling at any time. I provided a link to support the contention that all states bar the use of junk science. I have searched in vain for the link to the court's judgment in Price v. Phillips Morris. Accordingly, I will restore the link to the Phillip Morris case and try to address some of your concerns.

Whitfield Larrabee 23:35, 19 September 2005 (UTC)

One link to the Philip Morris case is plenty. I don't know why you insist on inserting a second link, especially when that second link is a pdf instead of html. I also don't know why you insist putting things in that aren't true, like the claim that "all medical malpractice is state law." See, e.g., the Federal Tort Claims Act. In addition, please observe the style rules for the talk section. It's not polite to put your comments at the top or to fail to indent appropriately. FRCP11 00:58, 20 September 2005 (UTC)

So Many Problems With This Entry .....

I am not sure it deserves inclusion since it is ambiguous by definition, defies widespread agreement as to what this particular phrase entails, and is used for political purposes to motivate voters and supporters. It may be explained no more reliably than if one attempted to explain what "compassionate conservatism" means. It obviously means different things to different people. I will be back to offer more specific suggestions later when I have more time.JFKer 01:00, 20 September 2005 (UTC)

A definitional examination of "Tort Reform" reveals it is a colloquial phrase which is empty, insubstantial and lacking meaning. In other words, it is inane. If we are going to have an encyclopedic entry for this phrase, then the definition of the terms should be considered from a neutral perspective, and from more than just one political perspective.
As per the Merriam-Webster Online Dictionary tort is defined as "a wrongful act other than a breach of contract for which relief may be obtained in the form of damages or an injunction" , and reform is defined as "to put or change into an improved form or condition." Therefore, the phrase created by the combination of these terms might be fairly described as "changing or improving a wrongful act ...." However, this definitional meaning does not describe the changes that this Administration is promoting when they use this phrase. A phrase which would accurately describe the changes this Administration wishes to enact would be "tort recompense restriction," but that does not roll off the tongue and does not lend itself to continuous repetition during countless sound bites. It would also expose to the public their true motives behind this effort.
You assert that "tort reform" refers to a concrete set of policy proposals. Hmmm .... I wonder if you might be referring to the many instances in which the ABA(American Bar Association) has appointed a panel of legal scholars to study the civil process and procedures governing the bringing of a tort claim, the standards of proof which must be met to establish the existence of that claim by the production and submission of a preponderance of relevant evidence, and the procedure for determining and assigning compensation responsibility to those individuals and/or entities who engaged in the tortuous act? I suspect you did not intend to refer to these specific "proposals" in making your assertion. Even so, these efforts and findings are equally entitled to be referenced as "tort reform" as much as "the concrete set of policy proposals" put forth by this Administration which you reference here.
Therefore, the only way to intelligently discuss "the concrete set of policy proposals" to which you are referring is to explain that the phrase "tort reform" is a slang expression created by its proponents for political gain to promote in a misleading way the policy of restricting court access to, and court award of full and fair compensatory damages to, individuals who have proven to the court's satisfaction that they were the victims of tortuous conduct committed against them by the named defendants.
I realize that the Bush Administration has raised to an art form the act of assigning names to things which purport to do one thing and in fact do the very opposite. For example, they name their law the "Clear Skies Act" when in fact it actually allows polluters to massively increase their disbursement amount and toxicity of air pollutants. In this case, the assigned phrase "tort reform" performs a similar function.
For the foregoing reasons, I submit that the entry titled "tort reform" does not deserve a separate entry. I have no problem with discussing any policy objective of this or any other Administration which is properly defined and referenced. However, I do question your assertion that this is "a topic at the top of the domestic policy agenda of this administration..." as I see no evidence that it is being promoted and pushed as the top issue by this Administration. Social Security, permanent repeal of estate and gift tax, permanent taxcuts for the rich, energy policy, the war in Iraq, etc. all seem to be higher on this Administration's agenda. I also question a policy which bestows validity upon an entry here simply because a certain number of wikipedia editors contribute to a proposed entry. If that were the standard, all I would need is "dozens of editors" to contribute to an entry entitled "Jolly Green Giant Terrorism" for it to make its way into this encyclopedia!
In regard to your assertion that I had "problems" with my last set of edits, I was not aware that debating, discussing and persuading other wikipedia editors to adopt a modified version of your proposed edits was a "problem." I was under the assumption that such was the standard operating procedure at Wikipedia where individual editors are not in total agreement as to a proposed set of edits. ("And by the way, that is how Congress operates as well .... compromise"). Kudos to my fellow Wikipedia editors who are attempting to "catch lightning in a bottle" in trying to define this entry.JFKer 14:12, 22 September 2005 (UTC)
Sir: you may be correct that, as a semantical matter, "tort reform" should be used to describe what you think it should, and that politicians and journalists are wrong to do otherwise. But Wikipedia is descriptive, not prescriptive, so your comments are inapposite to whether there should be an entry here.
Similarly, anti-Semitism refers to a concept distinct from opposition to Semites. That doesn't mean there shouldn't be an "anti-Semitism" entry on Wikipedia, just because the word "anti-Semitism" doesn't correspond to the word elements that make it up.
You may or may not be interested to know that I don't like the term "tort reform" and don't use it myself when discussing the underlying issue. But I don't get to impose my lexical preferences on Wikipedia, and neither do you. FRCP11 17:41, 22 September 2005 (UTC)

Apology

I meant to write "remove redundancy" and inadvertently wrote "remove vandalism" in my description of an edit fixing yet another time that Whitfield Larrabee placed the same thing in an article twice. I didn't mean to accuse him of not acting in good faith, but the carelessness in his edits is really getting to be annoying. FRCP11 20:05, 20 September 2005 (UTC)

I did discover that there is a link to the decision, as you asserted, so I will not make this error again.

--Whitfield Larrabee 02:18, 21 September 2005 (UTC)

Caps on non-economic damages

This section does not even pretend to be NPOV. Please stop vandalizing the article and clean up your mess. -- FRCP11 03:55, 30 September 2005 (UTC).

The examples are taken from cited sources and accurately set for the position of opponents of tort reform. Accurately stating the points of view of opponents of tort reform is not point of view. The McDougal case has been widely reported. The illustrations of how caps are utilized are accurate. I note that FRCP11 had no objection to the McDonald's coffee case example, widely circulated by "tort reformers" and that he also relied on and introduced the case example in the Phillip Morris case. Since we are using cases and examples to illustrate the points of the "tort reformers", there should be nothing wrong with using actual cases and hypothetical examples to illustrate the application of damage caps.
FRCP11's use of terms such as "vandalizing" and the like to describe other's contributions to the article, while evidently considering that only his contributions to the article to be beneficial betrays an intolerance for the viewpoints and contributions of other editors to this topic.--Whitfield Larrabee 23:31, 30 September 2005 (UTC)
The McDonald's coffee case discussion is NPOV, because it includes both sides' characterizations of the case, and pre-dates any edits I made to the article (which puts the lie to your false claim that I'm intolerant of other viewpoints). Creating a new section of one sided arguments against a particular controversial issue in a section titled "debate" without acknowledging that there are two sides to the issue is POV. Note the difference.
I call it vandalism because your edits consistently fail to meet minimum Wikipedia standards, and it's getting really annoying having to clean up after you. You're not even trying to conform to the requirements of NPOV, avoiding original research, maintaining style consistency, accuracy, or bothering to spell words correctly. Again: are you going to clean up your mess? -- FRCP11 03:27, 2 October 2005 (UTC)