Wikipedia:Articles for deletion/Leal Garcia v. Texas


 * 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   keep. The nominator has stated that "a denial of petition is not notable" but has provided no solid reasoning for this, however there are plenty of comments that refute this and demonstrate the notability of the article. The subject has been covered in reliable sources, including those separate from the Supreme Court itself. Perhaps a merge to Humberto Leal Garcia, Jr. is something that can be discussed, but there's no consensus here to mandate that decision by AFD, so I'm closing as keep, with a merge possible through discussion. (non-admin closure) Steven Zhang  The clock is ticking....  00:50, 21 July 2011 (UTC)

Leal Garcia v. Texas

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Humberto Leal Garcia, Jr. is notable. The trial of Leal Garcia at the state level is notable. The U.S. Supreme Court's denial of his petition for habeas corpus is not notable, so this Leal Garcia v. Texas article should be deleted or merged into Leal Garcia's article. The U.S. Supreme Court's denial of the petition is not an actual U.S. Supreme Court case. Granting the petition would have granted permission for a U.S. Supreme Court case, so the Court's denial of the petition was the Court's refusal to hear the case. OCNative (talk) 08:18, 13 July 2011 (UTC)
 * Keep/Comment (Disclosure: I created the article) This article is notable for numerous reasons. First, as is clear from the numerous news reports available, Leal Garcia v. Texas has received WP:SIGCOV from many WP:RS. Per WP:GNG, I think that fact alone proves WP:N, but I will present a few supporting arguments. Per WP:NBOOK, books are often considered notable if "the author is so historically significant that any of his or her written works may be considered notable". The per curiam opinion was written by five United States Supreme Court Justices and the dissent was written by four Justices. Clearly these written works were authored by those so historically significant that they qualify under WP:NBOOK. A final argument is that this qualifies under WP:EVENT because of WP:EFFECT. As stated, "events are often considered to be notable if they act as a precedent or catalyst for something else. This may include effects on the views and behaviors of society and legislation. ". Legislation is being enacted in part because of this decision.
 * Now that I've presented my case for WP:N, I'd like to try to understand your case against it. From what you wrote, it seems your argument is that it is not notable because it is not a United States Supreme Court case. However, I'm am not aware of a guideline that specifies this is a mark against notability. Why specifically do you think WP:N is not satisfied? Sailing to Byzantium (talk) 09:57, 13 July 2011 (UTC)
 * As I said, Leal Garcia and his state trial are notable, as those are what are getting the significant coverage. WP:NBOOK does not apply to this denial by the federal Supreme Court because this was not a book.  Actual decisions in actual cases by the Supreme Court are notable, denials of petitions are not.  Legislation is not being enacted because of this denial of the petition; the legislation was already being considered before the denial of the petition.  The reason I brought up the fact that this is not a Supreme Court case is because the article's wording would lead a reader to believe it is a Supreme Court case.  This is an article about a denial of a petition, and a denial of a petition is not notable. OCNative (talk) 10:38, 13 July 2011 (UTC)
 * Alright I'll simplify my stance because I'd rather not get bogged down in splitting hairs. The Supreme Court decision has clearly gotten WP:SIGCOV that is separate from the state trial (1, 2 3, 4, etc....). I've provided sources and if you disagree you're going to have to provide evidence that this isn't the case.  You keep saying things like "a denial of a petition is not notable" and I don't think that's productive. Do you understand why it's an arbitrary statement?  Anything at all can be notable if it satisfies the guidelines. Per WP:GNG I've clearly established a case for WP:N. Anything that has WP:SIGCOV "is presumed to satisfy the inclusion criteria for a stand-alone article or stand-alone list." Sailing to Byzantium (talk) 11:14, 13 July 2011 (UTC)


 * Note: This debate has been included in the list of Law-related deletion discussions.  —OCNative (talk) 10:38, 13 July 2011 (UTC)
 * Note: This debate has been included in the list of Crime-related deletion discussions.  —OCNative (talk) 10:38, 13 July 2011 (UTC)


 * Keep clearly notable court case. Has reached all levels of notability.--BabbaQ (talk) 11:16, 13 July 2011 (UTC)
 * Merge or keep. Normally, denials of petitions don't merit separate coverage because they are simple orders, and the Supreme Court issues thousands of them.  Even when a denial order provokes a dissent, as this one did here, we still don't normally have an article for the case, but can describe that dissent in a list of opinions by the authoring justice for that term.  Breyer's dissent in Leal Garcia is already listed at 2010 term United States Supreme Court opinions of Stephen Breyer (where it is awaiting a summary paragraph).  It's simply not accurate to dismiss this opinion as nothing but a petition denial, however.  First, the Supreme Court included it in its list of opinions for the term,, not in its tables of mere orders.  Second, it's clearly more substantive than a mere order, which would have contained nothing more than the last paragraph of the Court's opinion here blandly describing what action was taken without explanation ("The applications for stay of execution...are denied...", etc.).  The Court issued a four-page opinion discussing the substantive legal issues underlying its decision.  We do presume, and rightly so, that Court opinions are notable, because with few exceptions, they will get significant coverage in both mainstream media and specialist law sources. The "few exceptions" are per curiam opinions, which tend to be shorter like this one, or often look like one-line orders.  So the standard procedure is to describe them in mass lists, and Leal Garcia has a section awaiting expansion at 2010 term per curiam opinions of the Supreme Court of the United States (I forgot to create a redirect when I added it there).  So given that there is that venue for discussing this Supreme Court opinion, and Humberto Leal Garcia, Jr. basically functions as a main article for all of the legal proceedings, a standalone article is not necessary for the Supreme Court opinion, which as properly noted above was just one stage in a lengthy prosecution and post-conviction litigation.  But whether the Supreme Court's per curiam opinion only merits discussion in those articles I mentioned above, or also a standalone article, is an editing decision that didn't need to be taken to AFD.  In its current state, I think it could easily be merged into the per curiam list, but I don't have an opinion on its expansion potential.  postdlf (talk) 15:12, 13 July 2011 (UTC)
 * Keep There appears to be enough commentary on this decision to fill out an article on the topic, particularly Cohen's piece in The Atlantic. No prejudice towards a Merge as an editorial decision, but I don't think there's any reason we must get rid of this article. Qrsdogg (talk) 17:01, 13 July 2011 (UTC)
 * Strong keep. Even absent the media coverage, any SCOTUS action that comes with an issued opinion of some length, even a unanimous per curiam (i.e., San Diego v. Roe, which is currently in a list but could support its own article), much less one with dissents (Toolson v. New York Yankees) is inherently notable as binding legal precedent on every other American court. Not to mention that such opinions are often discussed in notable law reviews. Daniel Case (talk) 18:22, 13 July 2011 (UTC)
 * Merge to Humberto Leal Garcia, Jr. per WP:OR/WP:PRIMARY which states: "Do not base articles entirely on primary sources." The only secondary source in the article is once citation by The Guardian. Location (talk) 13:22, 15 July 2011 (UTC)
 * I've added several secondary sources to the article in an attempt to address this concern. Note that recent SCOTUS cases do rely in part on WP:PRIMARY, which is acceptable when used carefully. I'm happy to address any specific instances of misuse. Sailing to Byzantium (talk) 13:42, 18 July 2011 (UTC)
 * This discussion will most likely end in a No Consensus decision so you/we will have time to improve the article.--BabbaQ (talk) 16:37, 20 July 2011 (UTC)
 * No WP:CONS with 4 Keep, 1 Keep/Merge, 1 Merge, and 1 Delete ? Seems like the AfD should be closed and any discussion of Keep/Merge should be moved to the talk page. Sailing to Byzantium (talk) 17:12, 20 July 2011 (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.