Talk:Heffernan v. City of Paterson/GA1

GA Review

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Reviewer: Notecardforfree (talk · contribs) 20:06, 7 May 2016 (UTC)

Preliminary comments

I will be completing this review over the course of this weekend, but I want to begin with a few preliminary comments:

• I already reviewed this article for its DYK nomination, and I think this is generally in good shape for passing the GA review as well.
• I am excited to see that the article is using Bluebook style citations! Many thanks to Wugapodes for their efforts creating Bluebook style templates. However, the case title should not be in Bold text; rather, bluebook requires that case titles be underlined or italicized (in articles, they should generally be italicized). This is not a GA requirement, but I thought I should let you know.

Look for a complete review later this weekend. Thanks so much for your efforts to improve this article! Best, -- Notecardforfree (talk) 20:06, 7 May 2016 (UTC)

The bolding was an issue with {{Ussc}}, it has been fixed. Wugapodes (talk) 00:10, 8 May 2016 (UTC)

Full review

Rate	Attribute	Review Comment
1. Well-written:
	1a. the prose is clear, concise, and understandable to an appropriately broad audience; spelling and grammar are correct.	For the most part, the article is clear, precise, and well-written. However, see my comments for portions of the article that still require clarification. All issues have been resolved.
	1b. it complies with the Manual of Style guidelines for lead sections, layout, words to watch, fiction, and list incorporation.	This article complies with relevant portions of WP:MOS. However, see my comments below for a suggestion about the ellipse in the block quotation that appears in the "Opinion of the Court" section.
2. Verifiable with no original research:
	2a. it contains a list of all references (sources of information), presented in accordance with the layout style guideline.	See below in the comments section for passages in which citations require clarification. All issues relating to citations have been resolved.
	2b. reliable sources are cited inline. All content that could reasonably be challenged, except for plot summaries and that which summarizes cited content elsewhere in the article, must be cited no later than the end of the paragraph (or line if the content is not in prose).	The author utilizes reliable sources. No issues here.
	2c. it contains no original research.	No concerns about original research.
3. Broad in its coverage:
	3a. it addresses the main aspects of the topic.	Excellent work expanding this article. I think this article's coverage of this topic is sufficiently broad for the purposes of the GA Criteria.
	3b. it stays focused on the topic without going into unnecessary detail (see summary style).	This article does not lose focus.
	4. Neutral: it represents viewpoints fairly and without editorial bias, giving due weight to each.	I don't think there are any problems with neutrality. However, as discussed in further detail below, you should add commentary that is critical of the Court's opinion if you can find any.
	5. Stable: it does not change significantly from day to day because of an ongoing edit war or content dispute.	There have been no conflicts with respect to this article's content.
6. Illustrated, if possible, by media such as images, video, or audio:
	6a. media are tagged with their copyright statuses, and valid non-free use rationales are provided for non-free content.	This article makes good use of images and there are no issues with copyright, etc.
	6b. media are relevant to the topic, and have suitable captions.	The images and their captions are appropriate.
	7. Overall assessment.	See comments below for a few issues that should be resolved before this article is promoted. This article satisfies all GA criteria. Congratulations!

Comments from Notecardforfree

My apologies for not returning to this review sooner. My in-laws came to visit for Mother's Day and I've been swamped with work this week. In any event, I think this is a very nice article and an excellent addition to the encyclopedia. I think it is very close to being ready for promotion to GA status, but I have highlighted a few issues that should be resolved first:

Lead

• In the lead, you state that "The court reversed an earlier holding to the contrary by the Third Circuit Court of Appeals." I assume you are talking about Ambrose v. Robinson Township. However, I don't think Justice Breyer's opinion ever explicitly stated that Ambrose was no longer good law (in fact, Ambrose is only mentioned once, in a parenthetical citation on page three of Justice Breyer's opinion). I agree that Ambrose likely holds little weight after Heffernan, but because SCOTUS did not explicitly disapprove of the case (and because it may be distinguishable on other grounds), we probably shouldn't say that SCOTUS "reversed" the case.

Done Wugapodes (talk) 17:22, 13 May 2016 (UTC)

• Also in the lead, you say that Heffernan "picked up a lawn sign for the candidate challenging the city's incumbent mayor in the 2005 election ...." Do you think there is any danger that readers may think that Heffernan was picking the sign up off the ground (rather than collecting it at a distribution center)? If you think there is little chance for confusion, then I would keep it as-is.

Done Wugapodes (talk) 17:22, 13 May 2016 (UTC)

History

• The first two sentences of this sections state: "The case took a decade to reach the Supreme Court. For most of that time it was in federal district court, where it was heard by three different judges." At the end of that paragraph, you provide a citation to the Third Circuit's opinion. However, that opinion says nothing about the length of time it took for the case to reach SCOTUS, that it was in district court most of that time, or that the case was heard by three judges. Can you provide citations to substantiate these three pieces of information?

Not Done. This seems like simple math and common sense here. The dispute started in 2005, it got to SCOTUS in 2015. It was in the district court from 2005 until 2014 (with some Third Circuit action in between) which I think anyone would describe as "most". We describe the three different judges, each of which has a citation. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

Fair enough. My concern would simply be that readers who are unfamiliar with the way cases work may expect to find all of this information in the the Third Circuit's opinion, though the logic in your comment is sound (it really is common sense). -- Notecardforfree (talk) 18:31, 13 May 2016 (UTC)

• When discussing Heffernan's demotion, is it worth mentioning that he was demoted to a "walking post?" Right now, the article says that he was demoted to a "patrol" position, but I'm not sure that "waking post post" is synonymous with a "patrol" position.

Not Done (yet). I think I saw a source that called it a patrol position. I'll try and find it and if not switch it. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

It is possible that a "patrol" position is synonymous with a "walking post," though when I think of police officers "patrolling," I envision officers driving around in police cruisers. -- Notecardforfree (talk) 18:33, 13 May 2016 (UTC)

• In the paragraph that begins with "Judge Cavanaugh granted summary judgment ...." you say that the Third Circuit remanded the case "with instructions to allow Heffernan to present his freedom of association claim and consider the facts from the jury trial"; however, it sounds like the district court was told that it was free to consider evidence (not that it was required to consider that evidence). Can you clarify this point in the article?

Done. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

• In that same paragraph, you support all factual assertions by citing to the 2014 Third Circuit opinion. Can you include an explanatory parenthetical statement at the end of the citation that explains the 2014 opinion is citing the 2012 opinion?

Done. I think. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

• In the subsection titled "Supreme Court," the article says that "The United States government also filed an amicus brief, meaning the Solicitor General's office would be appearing at oral argument ...." To me, this implies that the Solicitor General was allowed to appear during oral arguments because they filed an amicus brief, but that's not what happened in this case. On December 21, 2015, the Solicitor General filed a motion asking permission to appear at oral argument, and that motion was granted on January 8, 2016. Can you clarify that the Solicitor General appeared at oral argument because the Court granted a motion that permitted them to do so?

Done. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

Opinion of the Court

• In the block quotation, you include an ellipse inside brackets. Per MOS:ELLIPSES, I don't the bracket is necessary because you are not quoting other ellipses in this passage.

Not Done. While the MOS is good to know, since SCOTUS decisions frequently use ellipses, making it unambiguous that this is an editorial omission not part of the text is, in my opinion, useful. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

That's a good point. -- Notecardforfree (talk) 18:36, 13 May 2016 (UTC)

• This is sufficiently detailed for the purposes of this GA review, but if you plan to nominate this for FA status in the future, then you should expand the discussion about the majority and dissenting opinions to say more about the methodological foundations of those opinions and the reasons why they reached their respective conclusions. For example, you will also want to include information about Justice Breyer's "costs to the employer" argument (slip op. at 7-8).

Will do! Wugapodes (talk) 17:22, 13 May 2016 (UTC)

• When discussing Justice Thomas' Fourth Amendment analogy, the article says "people stuck in traffic who were injured by unconstitutional actions would not be able to sue because none of their rights were violated." Can you clarify the language here? Justice Thomas said that the hypothetical law could cause collateral damage (e.g. in the form of traffic delays), but such harms caused by traffic delays would not be a direct result of that law. Can you make sure this distinction is clear in the article?

Done. I think Wugapodes (talk) 17:22, 13 May 2016 (UTC)

Commentary

• The article says that "Edelman forwarded interpretations of Heffernan's actions ...." Can you use a different word than "forwarded?" The meaning of this sentence is a little unclear to me.

Done. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

• The article states that "the decision was largely praised." This may be true, but it would be great to include commentary that is critical of the opinion for the sake of balance. Of course, if only a minority of commentators have expressed criticism, it should be given its due WP:WEIGHT.

I honestly have yet to find any negative commentary on the ruling. The Breitbart article I posted on the talk page read as critical but never actually said anything negative about the decision. If you know of any I'd gladly include them but even a Google News search today didn't turn up anything. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

Yeah, I haven't been able to find anything either; I simply meant that if you happened to know of anything, then you should include it. I'm honestly a little surprised this case sin't getting more press coverage. It is such an interesting case, and the press usually likes to cover issues that involve the application of the First Amendment in the workplace. -- Notecardforfree (talk) 18:35, 13 May 2016 (UTC)

Citations

I want to preface these comments by noting that the Good Article Criteria say that "[i]n-line citations should preferably be of a consistent style." (See criterion 2(b); emphasis is my own). That said, minor deviations in style will not be fatal to this GA review, but I think you should certainly try, to the extent that it is possible, to follow a consistent style. If you want to use Bluebook, then you should make sure that citations conform to relevant Bluebook conventions. The following comments discuss conventions for Bluebook style citations, but I am happy to answer any questions you may have about Bluebook citations:

• After you provide a full citation to a case, you can use short-form citations in subsequent footnotes (see, e.g., footnote 1, where a full citation is repeated twice). For short-form citations to the circuit court opinions, be sure to include info about the citation in the Federal Reporter so that readers know that you are citing to one of the circuit court opinions, rather than the SCOTUS slip opinion. For example, a short form citation to the 2015 3d Cir. opinion would look like this: Heffernan, 777 F.3d at 149.
• The proper Bluebook full-form citation to the slip opinion for this case is Heffernan v. City of Paterson, No. 14-1280, 578 U.S. ___, slip op. at [insert page number or page range] (2016). The short-form citation to the majority opinion is Heffernan, slip op. at [insert page number or page range]. The short-form citation to Justice Thomas' dissenting opinion should look like this: Heffernan, slip op. at [insert page number or page range] (Thomas, J., dissenting).
• When citing to a source that is available in print, you don't need to include a URL in the citation. If you do, the words "available at" (in italics) should precede the URL (see this explanation at pp. 2-3). However, because Wikipedia's internal style guidelines disfavor the clutter created by bare URLs, I think it is okay to simply turn the title of the source into a hyperlink that directs readers to the source.

I have updated {{ussc}} so that it can format short citations and updated the article accordingly. I agree the bare urls were unsightly, and so {{bluebook website}} has been updated as well to remove them. If there are other citation issues feel free to bring them up. Wugapodes (talk) 17:22, 13 May 2016 (UTC)

Thanks for your diligent work with citations for this article and for your incredible work with the templates! Everything looks good here. -- Notecardforfree (talk) 18:37, 13 May 2016 (UTC)

Please let me know if any of these comments are unclear or if you have any questions. Thanks again for your incredible work with this article! Best, -- Notecardforfree (talk) 00:02, 12 May 2016 (UTC)

@Wugapodes: Thank you for your incredible work with this article! I am pleased to announce that is has passed this GA review. Your work with SCOTUS articles and citation templates is truly admirable. Hopefully we will see many more excellent articles from you in the future! Best, -- Notecardforfree (talk) 18:40, 13 May 2016 (UTC)