Wikipedia:Articles for deletion/Robert Provan


 * 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. Overall consensus is for article retention. The notion of potentially renaming and repurposing the article to focus upon the legal case can continue to be discussed on the article talk page if desired. North America1000 22:00, 9 May 2016 (UTC)

Robert Provan

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Per WP:NOTOBITUARY, t This article gives no indication of its subject's notability apart from his having been supposedly the first lawyer to make a case based on a certain law that was passed (we probably do not have articles on the equivalent lawyer's for 99.999% of all laws that have been used in court cases) and does not cite any sources. It is also written like an obituary ("He is survived by his daughter, Michelle (age 22)"), which makes me suspect either that its author knew the subject and wished to immortalize them on Wikipedia, or copy-pasted it from a newspaper obituary, and I don't know which is a better argument for deletion. Hijiri 88 ( 聖やや ) 07:07, 2 May 2016 (UTC)
 * On the Fence : Stories that have some focus on the subject include WSJ, American Bar Association Journal, Houston Chronicle, Nevada Daily Mail (and by reference, MSNBC), and Texas Medical Association. Now it could be argued that coverage is close enough to WP:BIO1E, that the case (ZAMORA-QUEZADA v. HEALTHTEXAS MEDICAL GROUP?) is sufficiently notable, and that he could be satisfactorily integrated and redirected there -- however note that the case, which was settled out of court, does not appear at Americans with Disabilities Act of 1990 and does not yet exist on Wikipedia. ~Hydronium~Hydroxide~(Talk)~ 08:38, 2 May 2016 (UTC)
 * Keep I've rewritten this entire article adding references and citations. This articles subject filed a first of its kind lawsuit in the US that has been cited in other cases, and a WP legal expert should review it. Thanks. Picomtn (talk) 10:41, 2 May 2016 (UTC)
 * Note I believe this articles subject falls under Notability (people), but would appreciate other opinions on this. Thanks. Picomtn (talk) 11:23, 2 May 2016 (UTC)
 * Then why not rename and rewrite the article to be about the event rather than a biographical article? Most of the sources you added are about the legal case and either don't mention Provan at all or only mention his name once or twice, and two of the ones that are about him don't give us any significant biographical coverage beyond the fact that he was a polio survivor. Hijiri 88 ( 聖やや ) 23:58, 2 May 2016 (UTC)
 * Did you mean creating Rogers v. CIGNA Healthcare of Texas? You have to talk to "WikiProject Law" people about articles about separate legal cases. I guess it must be a really high-profile case. As a layman, I don't see much coverage. Staszek Lem (talk) 00:21, 3 May 2016 (UTC)
 * By "it must be a really high-profile case" do you mean "it would need to be a really high-profile case (in order to get its own Wikipedia article)" or "I think this probably is a really high-profile case"? Modal verbs are confusing as hell. Anyway, if he is only notable for that one event, and that one event doesn't meet GNG, then logically how on earth could he meet GNG...? Hijiri 88 ( 聖やや ) 01:12, 3 May 2016 (UTC)
 * Sorry, unfinished sentence. My intention was your first guess. Staszek Lem (talk) 16:04, 3 May 2016 (UTC)


 * Keep The NOTOBITUARY argument is nonsense because we have a section on the main page specifically for recent deaths. This person clearly made a difference, was covered adequately in reliable sources and so there's no reason for us to delete these facts. Andrew D. (talk) 12:06, 2 May 2016 (UTC)
 * Okay, fine -- how about "NOTMEMORIAL"? The article as I nominated it was an unsourced piece about what a wonderful man he was and was taken before his time. And even now it is essentially unsourced as a biography and should be probably be at least moved to a different title and rewritten to be about the only event for which he is notable. And rather than criticizing my delete rationale based on a philosophical interpretation of something on the main page, you should read this and help us figure out the mystery of the title blacklist that only affects some autoconfirmed users and not others. :P Hijiri 88 ( 聖やや ) 23:58, 2 May 2016 (UTC)


 * Delete A clear case of WP:1E. Paragraph 2 gives an exception: the event be "highly significant". I don't see how a layer's witticism is highly significant, unless explicitly declared so in WP:RS. Staszek Lem (talk) 23:49, 2 May 2016 (UTC)
 * Hi I don't know if you understood me, but when I mentioned WP:1E it was not for the purpose of validating this articles subject as he already meets WP:BASIC by the WP:RS sources The Wall Street Journal, Houston Chronicle and American Bar Association that were written about him and sourced in this article. Thanks. Picomtn (talk) 10:26, 3 May 2016 (UTC)
 * You appear to be new to this, so I will explain: WP:1E is more commonly cited as a rationale in favour of deletion and/or merging, so your comment citing 1E above in defense of this article remaining as is was actually a bit confusing for me. Hijiri 88 ( 聖やや ) 11:10, 3 May 2016 (UTC)
 * Hi Actually I was aware of this, but decided to bring this issue up before anyone else did so it could more fully discussed here. Also, thank you so much for your nomination for deletion of this article, otherwise it wouldn't have been found, and improved, by those like me. Thanks. Picomtn (talk) 11:16, 3 May 2016 (UTC)
 * Well, if bringing it up before anyone else was your goal, you were two hours late. And thank you for thanking me. As I said elsewhere, the article was essentially an orphan (only being linked to from the disambig page Provan). I found it by accident when trying to figure out if this author had a Wikipedia article. :P Hijiri 88 ( 聖やや ) 11:40, 3 May 2016 (UTC)


 * Note Hi (cc ) I'm not really sure about the NOTOBITUARY issue you're discussing, but it simply doesn't apply to this article I believe. Please allow me to explain. Going with the fact that WP has become a major primary/secondary research tool (Researching with Wikipedia) for students that even Harvard University admits can be used for basic research. I believe it's necessary for us to understand articles such as this in their most expansive context. For example, anyone doing ADA research would find this article invaluable as it pertains the history/genesis of lawsuits against it, most particularly due to its David v. Goliath aspects as it regards this articles subject. What are your thoughts. Thanks. Picomtn (talk) 11:01, 3 May 2016 (UTC)
 * I already specified that I'm not interested in discussing whether obituaries are allowed on Wikipedia, but WP:NOTMEMORIAL is pretty clear, and until your recent edit (which essentially constitutes OR, synthesizing this biographical article with a lot of content on the one event for which this person is known that isn't directly relevant to this biography) the article was unambiguously an obituary for the guy. Hijiri 88 ( 聖やや ) 11:07, 3 May 2016 (UTC)
 * Hi I'm confused by your WP:OR comment as I did no new analysis, or synthesis, of the published material about this articles subject. In fact, no OR was even needed as what these sources said is exactly what was put into my rewrite of this article, and as anyone can plainly see. Thanks. Picomtn (talk) 11:32, 3 May 2016 (UTC)
 * Attempting to pad an article out with material on related topics gleaned from a variety of sources that either don't mention or barely mention the main topic is IMO a form of OR. Hijiri 88 ( 聖やや ) 11:35, 3 May 2016 (UTC)
 * Hi Can you cite just one example of this being in this article please? Thanks. Picomtn (talk) 11:41, 3 May 2016 (UTC)
 * This thread is becoming TLDR, so I don't want to respond any more, and I think you will agree, so please don't ping me again and keep any more comments as brief as possible. This source lists his name briefly along with a bunch of others; this source doesn't appear to mention him at all; ditto this source; and this; and this as well. Therefore, any material taken from any of these five sources is not directly relevant to Provan's biography and does nothing to demonstrate his independent notability. That's almost half of the article (5/11 of your sources) that is essentially WP:SYNTH. Your obscure citation style makes it extremely difficult to establish which material you took from which source, so number-crunching is the best I can do without a greater time sink than I am willing to give this article. Hijiri 88 ( 聖やや ) 11:52, 3 May 2016 (UTC)
 * Now that I think of it, the two obituaries and the Texas State Bar also don't help the GNG/BIO1E case, and the three remaining sources all being news pieces from 1999-2000 seems to demonstrate that Provan is only notable for one event, and so the event, not the man, should be the one with an independent article. Hijiri 88 ( 聖やや ) 12:04, 3 May 2016 (UTC)
 * Hi If you're refereing to the sources linked to "have been cited in other court cases since", they are a  Consensus issue I've addressed in Wikipedia talk:WikiProject Law and Talk:Robert Provan as legal expert guidance is needed here. Thanks. Picomtn (talk) 11:59, 3 May 2016 (UTC)
 * I already asked you to stop pinging me. And yes, if you say "it has been cited in other court cases since" and cite those court cases yourself, that is textbook OR. Hijiri 88 ( 聖やや ) 12:04, 3 May 2016 (UTC)


 * Question - Maybe I'm missing some crucial points, but it seems like if we have a case of WP:1E, the next logical question is whether it can be turned into an article about that one event (the case) -- or whether it already exists. I see it's come up a few times, but most arguments are still about the BLP. Is there strong opposition to turning this into an article about the case? Doing so would benefit from, but is not dependent upon, folks from WikiProject Law, who can always renominate the case article if it's inappropriate. Seems like the best option to keep the content without keeping the biography. &mdash;  Rhododendrites talk  \\ 14:50, 3 May 2016 (UTC)
 * Hi Can, or should, a legal case be separated from its originating attorney is the first question I asked myself about this articles subject. The answer I came up with (following WP:BASIC) was yes due to the unique aspect of this attorney having a childhood disease thus allowing him to view the issue(s) presented to him in a context different than any of his peers. Remember, the ADA had been law for 6 years and no other attorney, in the entire US, had even contemplated such a novel (NYT word, not mine) lawsuit. How many other examples are there of attorneys, such as this one, who changed things due to their viewing something through the prism of their unique life history and experience, one might ask. So, I can absolutely envision a future dissertation (or other such academic paper) being written about attorneys such as this one (and there are many of them) making this articles subject, I believe, important to be included here. What are your thoughts? Thanks. Picomtn (talk) 10:40, 4 May 2016 (UTC)


 * Weak Keep with a tentative preference to Rename the article to be about the case, following the guidelines at WP:1E, and pending responses to my question above. The sources are in many cases about him, and when a person is profiled in several major publications it becomes less clear whether it's the person or the event that should have an article. WP:1E says we should default to the incident, though. &mdash;  Rhododendrites talk  \\ 14:55, 3 May 2016 (UTC)
 * Keep – There are now two solid references to support his notability. I am sure there are a couple of more to even bolster his notability and to allow expansion of the already adequate article. Cheers!  19:06, 3 May 2016 (UTC)
 * Keep There are sources if you look for them; I've just added another to support the claim that he was an assistant attorney general for Texas. WhatamIdoing (talk) 07:36, 5 May 2016 (UTC)
 * Note: This debate has been included in the list of Law-related deletion discussions. ~Hydronium~Hydroxide~(Talk)~ 13:03, 4 May 2016 (UTC)
 * Note: This debate has been included in the list of Law-related deletion discussions. ~Hydronium~Hydroxide~(Talk)~ 13:03, 4 May 2016 (UTC)


 * Uncomfortable Keep: There's appears to be enough sourcing out there to have some article, though expert care is sorely needed since the current one looks like it's possibly incorrect. There's two relevant cases -- Zamora... is from 1998 and Rogers... from 2001 -- and some sources (eg: the WSJ and Texmed) refer to the former. Can change vote to Uncomfortable Redirect if the latter case is agreed to be a continuation of the former, with the two incorporated into the one case article. Even if that could be done, however, BIO1E is a guideline and a separate BIO article could be kept if it's the cleanest implementation. ~Hydronium~Hydroxide~(Talk)~ 13:56, 5 May 2016 (UTC)
 * Hi You are correct that Zamora came first, and I've changed the articles section name to reflect this and added sources and changed the content wording to reflect this too. As for firmly connecting Zamora and Rogers, I'm still working on this issue and it's going to take a while as there are many pages of legal documents I'm still reading through. Thanks. Picomtn (talk) 23:38, 5 May 2016 (UTC)


 * Keep and make changes however needed, this seems convincing enough. SwisterTwister   talk  06:18, 9 May 2016 (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.