Wikipedia:Articles for deletion/Ney v. Landmark Education Corp.


 * 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 delete.  Sandstein  12:16, 29 September 2017 (UTC)

Ney v. Landmark Education Corp.

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Notability / BLP Issues Elmmapleoakpine (talk) 21:48, 13 September 2017 (UTC)

Delete I think this article first and foremost fails Notability, https://en.wikipedia.org/wiki/Wikipedia:Notability however there are issues with a number of other Wikipedia policies. It also violates WP: BLP.

WP: Notability -–See below regarding the minimal sourcing. This article is about a small civil case that came to nothing. The defendant named in the article was dismissed from the case before it went to trial and the plaintiff lost both the case and a subsequent appeal. Why does it warrant an article? WP-BLP - This is one of many articles created by a desysopped admin: Cirt. Prior to being removed from adminship and blocked from editing on BLPs, Cirt created numerous articles about people within the anti-cult movement as well as well as people criticized by the anti-cult movement. Werner Erhard, who is mentioned in this article, was a particular target of Cirt’s campainging. Cirt used his adminship to control articles and bully other editors. This abuse of Wikipedia came to end when Cirt lost his adminship and was banned from BLPs and these topics. Elmmapleoakpine (talk) 22:01, 13 September 2017 (UTC)
 * Poor Sourcing- The article relies on several unreliable and primary sources 1) The book Outrageous Betrayal by Steven Pressman is effectively hearsay and contains almost no citations or footnotes. 2)The Cult Observer website/newsletter does not qualify as a reliable source. 3) In total there are only two reliable secondary sources here, not enough to consider this noteworthy.
 * Note: This debate has been included in the list of Law-related deletion discussions. Shawn in Montreal (talk) 22:20, 13 September 2017 (UTC)
 * Note: This debate has been included in the list of United States of America-related deletion discussions. Shawn in Montreal (talk) 22:20, 13 September 2017 (UTC)


 * I don't recall the details about Cirt. Is there really no way he can even take part in this Afd? He wasn't notified. Shawn in Montreal (talk) 22:27, 13 September 2017 (UTC)
 * I've found the ruling at WP:RFAR: yes, Cirt is indeed banned from "new religious movement" topics. Shawn in Montreal (talk) 00:07, 14 September 2017 (UTC)
 * Delete. Run-of-the-mill district court case, setting no precedent. Yes, it was appealed, but the district court's judgment was affirmed in an unpublished opinion that cannot be cited as precedent. The fact that the Fourth Circuit designated the opinion as "unpublished" (i.e. "the court deems the case to have insufficient precedential value") is evidence of its unimportance. The sources indicate it got some news coverage, but WP:NOTNEWS); the other sources appear to have axes to grind. Nothing to see here.
 * As an aside, the editors have been pretty imprecise in the content of the article. The Infobox calls the Fourth Circuit Court of Appeals unpublished opinion a "transcript" of the district court case, which it certainly is not; and the Court of Appeals opinion itself on Commons is misrepresented there as as coming from "United States District Court of New Jersey". This level of disregard for accuracy in what qualifies as a WP:BLP article (Erhard was a party to the case) concerns me and makes me wonder how accurately the cited sources are represented. TJRC (talk) 23:55, 13 September 2017 (UTC)


 * Keep Agree that notability is borderline, but notable enough to merit a Washington Post article at the time. I don't agree that sourcing is weak.  Everything significant in article can be found in the cited washington post or the Fourth Circuit opinions. I don't understand how this article purportedly runs afoul of WP:BLP  The misbehaviour of one of the editors who created strikes me as irrelevant to this discussion. Maybe the proposer will explain.  The inaccuracies referenced above should be corrected, but don't relate to the living person.  If an editor is concerned that a source is being misrepresented, he should look at the source, not have the article deleted.  (Not hard to do, it's in wikisources. I do agree that the case did not establish any significant legal precedent, and certainly doesn't meet the criteria in the WP:CASES guideline, but many cases that don't fall within that guideline are notable for other reasons, as this one seems to be, and have articles here.  Guideline should probably be amended. Federalist51 (talk) 01:14, 14 September 2017 (UTC)
 * Delete My look at the article is on two bases: that facts of the case, which are interesting and perhaps prurient. The article discusses these in depth and is sufficiently supported by references. The matter of law in the case is unremarkable, but not discussed in the article. Why did the case make it to the appeals stage? It really has nothing to do with the facts.  At issue was successor liability and personal injury. The PI claim was spurious at best. The matter of successor liability was dealt with in accord with existing law and precedent. Those two elements make the case not notable.  So we return to the facts: It is a soap opera story of a woman who went to an est seminar, confessed infidelities, had infidelities confessed to her, and went nuts. It's essentially an Enquirer story, and one damaging to a living person.  Keep it if you wish, but I would have hoped we didn't use an appeals case template to wrap it for WP readers. I rather doubt the article would have made it this far without the official looking packaging. Rhadow (talk) 12:45, 14 September 2017 (UTC)
 * "Why did the case make it to the appeals stage?". Basically, because the losing party chose to appeal. A losing party can appeal as of right; it doesn't mean the appeal has merit.
 * It's different at the Supreme Court stage, where, with some rare exceptions, a party must petition the court to hear the case; and the court says "nope, not interested," in something like 99% of the cases it's asked to hear. TJRC (talk) 00:36, 15 September 2017 (UTC)


 * Delete Insufficient coverage in reliable secondary sources. One newspaper mention and one other reliable source aren't enough. Even if they were accurately represented here, court papers are primary sources and don't establish notability. Also clearly doesn't meet WP:CASES. Nwlaw63 (talk) 01:28, 15 September 2017 (UTC)
 * Hello Nwlaw63 -- WP:CASES failed to achieve consensus, so I'm not sure it's an effective argument. Rhadow (talk) 03:50, 15 September 2017 (UTC)
 * Agreed. I'm simply pointing out that if one used that protocol, this still wouldn't be worthy of an article. Nwlaw63 (talk) 01:22, 16 September 2017 (UTC)


 * Merge/redirect to Landmark Worldwide. Noteworthy in context of company history only. Neutralitytalk 16:26, 16 September 2017 (UTC)
 * I don't see the value in a redirect in this case. The case is so minor it's not worth mentioning in the article on the company. It would probably get deleted from that article sooner or later, in which case we'd be left with a redirect that doesn't help anyone: if someone ever did search on the case, or find it in a google search, they'd be sent to an article that didn't even discuss it. TJRC (talk) 22:10, 19 September 2017 (UTC)


 * Delete Clearly fails on WP:Notability, and is also a coatrack with an agenda other than the ostensible topic of the article. DaveApter (talk) 15:51, 18 September 2017 (UTC)
 * Merge entire lede to Landmark Worldwide - this is a classic example of what that type of section is for. TimTempleton (talk) (cont)  21:26, 20 September 2017 (UTC)
 * TimTempleton If you would be willing, I invite you to consider the deletion proposal from this perspective: The case in and of itself, as multiple people have said, is not noteworthy, (the basis of my nomination). As to your proposal to merge; the events of the case took place before Landmark even existed, and the company was quickly removed from the case when it was found not to have successor liability. Landmark is almost a footnote to a case that while being salacious, had little legal significance.Elmmapleoakpine (talk) 21:55, 21 September 2017 (UTC)
 * User:Elmmapleoakpine Landmark was sued and then removed from the case when the Virginia court ruled that liability didn't carry from Erhard to Landmark, but that doesn't change the fact that it was sued, however unwelcome the suit was. The suit got media coverage - I just added the URL for the Washington Post coverage.  That's why I say take the lede in its entirety and merge.  It contains the qualifying details that a discerning reader can use to come to the same factual understanding. BTW - I made a minor modification to the lede after reading the appeal. TimTempleton (talk)  (cont)  22:59, 21 September 2017 (UTC)


 * Keep Borderline notability but never the less meets the notability in most respects.--INDIAN REVERTER (talk) 22:38, 20 September 2017 (UTC)
 * Above editor was blocked yesterday as a new account that immediately rapidly voted keep on numerous articles. TimTempleton (talk) <sup style="color:#7F007F">(cont)  15:31, 21 September 2017 (UTC)

<div class="xfd_relist" style="border-top: 1px solid #AAA; border-bottom: 1px solid #AAA; padding: 0px 25px;"> Relisted to generate a more thorough discussion and clearer consensus.

Please add new comments below this notice. Thanks, -- Patar knight - chat/contributions 03:19, 21 September 2017 (UTC)


 * Delete This is so not notable, is terribly sourced, and seems a clear candidate as a coatrack.  On top of that the events in the case happened before the company's existence!! Alex Jackl (talk) 17:59, 21 September 2017 (UTC)


 * Delete When I edited this in the past I thought it was a weak article to begin with. This case is not notable enough and was inconsequential. It therefore does not warrant a Wikipedia article.RecoveringAddict (talk) 17:40, 25 September 2017 (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.