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. (non-admin closure) Erik9 (talk) 00:57, 13 August 2009 (UTC)[reply]

Ernesto Miranda[edit]

Ernesto Miranda (edit | talk | history | protect | delete | links | watch | logs | views) (delete) – (View log)

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Nominated with:

Clarence Earl Gideon (edit | talk | history | protect | delete | links | watch | logs | views)

Miranda and Gideon were litigants in two very famous and notable cases, Miranda v. Arizona and Gideon v. Wainwright, but it's the cases bearing their names that are notable, not (without more) the litigants themselves. As WP:NRVE explains, the "notability of a parent topic ... is not inherited by subordinate topics," and WP:SINGLEEVENT makes clear that a separate article would only be warranted if they had done something else that makes them notable. Put another way, for these litigants to merit inclusion, they would have to be sufficiently notable to have an article even if the cases bearing their names didn't exist. Otherwise, they should be handled in our article on the case, and there only to the extent relevant to the case.

Neither of these articles meet that standard. They are a tailored fit for WP:SINGLEEVENT. I propose deletion or, in the alternative, merge and redirect to Miranda v. Arizona and Gideon v. Wainwright respectively.

Lastly, George W. Bush was a litigant in a famous and notable case, but if that was his sole claim to notability, we would not have an article on him; John Terry was a litigant in another famous and notable Warren Court criminal procedure case, but we don't have an article on him. Anyone remember the names of the named plaintiffs in Brown v. Board? Not only do we not have a separate article on them, our article on the case doesn't even name them. I realize that not many editors share my disagreement with WP:OTHERSTUFF, but I mention this for those who do. - Simon Dodd { U·T·C·WP:LAW } 00:23, 7 August 2009 (UTC)[reply]

• Keep nom. is strictly correct but these are such very famous cases that interest in who the plaintiffs were is natural; Miranda's name is synonymous with the outcome. Hence, I propose to err on the side of making WP useful by retaining these articles in a mild application of WP:IAR. For lesser cases I would concur with nom. JJL (talk) 01:43, 7 August 2009 (UTC)[reply]
  • Assuming for sake of argument that you're right about interest in the plaintiffs, is there a reason that such details can't be provided in the articles on the cases? I wonder if it might prove instructive to borrow an analytic structure from another context. WP:NSONG tells us that we should only have an independent article on a particular song "when there is enough verifiable material to warrant a reasonably detailed article"; if not, we should at most redirect to an article for the album containing the song, and there provide whatever coverage is warranted. In Wikipedia:Articles for deletion/Pull Me Under, I argued that we should understand NSONG as justifying a standalone article only when it can present well-sourced information that would violate WP:DETAIL if it was included in the article for the album on which it appears.

    Now, of course, I'm not suggesting that NSONG applies to these two articles. I wonder, though, if similar reasoning can help untangle WP:SINGLEEVENT's concern that "[w]hen an individual is significant for their role in a single event, it may be unclear whether an article should be written about the individual, the event or both." Assuming that there are no other justifications for a standalone article (WP:SPLIT, for example), I would suggest that when an individual is notable only for their role in a single notable event, and there is an article about the event, we should only have a separate article about the individual when it can present well-sourced information that would violate WP:DETAIL if it was included in the article about the event. Is that framework a good fit in this context, and if so, how do Mssrs. Miranda and Gideon fare by it?- Simon Dodd { U·T·C·WP:LAW } 02:18, 7 August 2009 (UTC)[reply]

    • I'm in basic agreement with your overall position. In the case of C. Gideon, given how the two articles are currently structured, I think the detail about his personal life and aftermath of the case might detract from the flow of that article. In the case of E. Miranada, adding to or splitting the "Effects of the decision" section at the case's article might make a merge workable. I do think someone looking up the names of these individuals should be redirected to a basic biography that includes their personal post-trial outcomes, which is not necessarily a natural part of the articles on the cases. JJL (talk) 03:14, 7 August 2009 (UTC)[reply]
• Keep These were very big cases, big enough that there is ample material on the litigants. And for whatever reason, these two were made famous by these cases more than most major Supreme Court litigants. Hundreds of gnews hits on each of them, it was news when they died. There is certainly enough reliably sourced info on them that all the details would be inappropriate for the articles on the cases, Anthony Lewis's Gideon's Trumpet foremost on Gideon. I don't think it is ignoring rules to keep them, because "If the event is highly significant, and the individual's role within it is a large one, a separate article is generally appropriate." John Z (talk) 03:37, 7 August 2009 (UTC)[reply]
• Either the people's lives and works are only documented in the context of the court cases, and a redirect is appropriate from these titles to the cases (per Wikipedia:Redirect#What do we use redirects for?), or there is enough documentation of these people's lives and works separate from the cases that involve them to warrant proper biographical articles about them. Either scenario is enactable via the ordinary editing tool. An administrator does not need to push a delete button either way. This is not a matter for AFD. Uncle G (talk) 11:02, 7 August 2009 (UTC)[reply]
  • Respectfully, it's a matter for AFD because I think the articles should be deleted, as the nomination explains, and that isn't "enactable via the ordinary editing tool." I will accept merge and redirect as an alternative to deletion, if the community disagrees with me that deletion is appropriate, but obviously we can't know what the community thinks until we've had a nomination. - Simon Dodd { U·T·C·WP:LAW } 13:22, 7 August 2009 (UTC)[reply]
    • Then you aren't using all of the tools in the toolbox, you haven't absorbed Wikipedia:Redirect#What do we use redirects for?, and you are mis-using AFD as a big hammer. If a person is dealt with in the context of a court case, we redirect from the person's name to the article on the court case, just as we redirect from sub-topics to articles on the enclosing topics. Deletion is not the only tool in the toolbox, and isn't even required to enact a redirect. If one wants to discuss redirecting something, one doesn't use AFD as a big hammer to start that discussion. One either boldly performs the redirect, or suggests it on the article's talk page to start discussion, using (say) RFC or the Wikipedia:Content noticeboard (or the Biographies of living person's noticeboard, or even the target article's talk page) to bring attention to that talk page if necessary. AFD is not RFC, nor a noticeboard substitute. It's not a big hammer, and it is not the only tool in the toolbox. Witness Talk:Conrad Murray#Redirect for an example of an article talk page discussion of redirecting a title to the enclosing subject. Uncle G (talk) 13:40, 8 August 2009 (UTC)[reply]
• Keep both. Not only were these cases leading cases in criminal procedure; these cases were so well known that they became household words and political issues. This level of attention, which rose well above the norm for parties in important cases, generated curiosity about the individual litigants. As such reliable sources stepped in to feed that curiosity. Thus it came to pass that these two drifters and petty crooks had the sort of attention paid to their lives that meets the basic standard for biography even if their chief claim to fame was only as parties to those cases. Note also that the "one-event" standard only applies to biographies of living people, and therefore not to either of these articles; BLP is at any rate an exception to the general standards of both notability and sourcing, and as such should be strictly confined. - Smerdis of Tlön (talk) 14:18, 7 August 2009 (UTC)[reply]
  • Just to address the last point: I think you're confusing WP:SINGLEEVENT, which is a part of WP:BIO and applicable to all biographical articles, with WP:BLP1E, a similar policy contained in WP:BLP that is applicable only to BLPs.- Simon Dodd { U·T·C·WP:LAW } 14:55, 7 August 2009 (UTC)[reply]
• Keep Meets WP:N, and I reject the notion that this long-running and very important case is a "single event" any more than, say, being a federal judge is a single event. Hobit (talk) 17:24, 7 August 2009 (UTC)[reply]
  • Then you should think again. This isn't about single events, this is about people who are only known about in the context of the court cases that surround them, and whose lives unconnected to those court cases are not documented. That we don't try to shoe-horn every subject in the world into individual biographies of the people involved in the subject, making those biographies one-sided and incomplete accounts of the actual overall subject, is one principle that underlies the BLP1E policy, and it is a principle that is not by its nature restricted to merely living people. The Glasgow Ice Cream Wars are not a "single event", as can be seen from the article, but many of the people involved in them are canonical examples of people who are solely known about in the context of the overall subject, and whose biographies, if written, would be nothing more than partial and one-sided accounts of the actual subject. And, conversely, some of the people involved in them are also known about in other areas.

    So the notion that you refuse to address is the notion that is actually at issue: whether these people are known about outside of the landmark court cases that involve them. And of course the proper venue for discussion of that, since the choice of outcome in such situations is between an article and a redirect, not involving deletion at any stage of the process, is the articles' talk pages. Uncle G (talk) 13:40, 8 August 2009 (UTC)[reply]

    • I don't see deletion as a reasonable outcome (100+ book cites, 70+ news cites, and *I*, random joe-blow. know who he is) which is what we are doing here. And this isn't a BLP, so BLP1E doesn't apply (and I don't agree with you that it should reach past living people). Nor was there a short flurry of coverage. As such I don't believe there is reason to delete this article. Now if there isn't RS information needed to write a reasonable biography (as you indicate), that would be different. But I, like you, believe that the article's talk pages are the right place for that discussion. Hobit (talk) 13:54, 9 August 2009 (UTC)[reply]

Hobit, like Smerdis of Tlön, you're confusing WP:SINGLEEVENT, which is a part of WP:BIO and applies to all biographical articles, with WP:BLP1E, a similar policy contained in WP:BLP that is applicable only to BLPs. I cited the former, so your argument that the latter doesn't apply is a strawman.- Simon Dodd { U·T·C·WP:LAW } 15:05, 9 August 2009 (UTC)[reply]

If the event is highly significant, and the individual's role within it is a large one, a separate article is generally appropriate. Is the event highly significant? Yes. Is Miranda's role in the event large? I'd say yes though I could see that as debatable.

Further, please note that the argument I'm replying to specifically refers to the BLP1E policy and argues to expand it. Thus I argued against a real argument by someone I respect (quite a lot actually) and therefor it isn't a strawman I'm arguing against... Hobit (talk) 17:39, 9 August 2009 (UTC)[reply]

May I remind everybody that we're not in a court of law and that the guidelines are not prescriptive? We're not trying to win a court case here. There has been no rationale given as to why the biography of Miranda or Gideon, both of which have been well-documented, should somehow be cleared out of the encyclopedia. Yes, there will be some redundancy between these articles and those about the cases but that's part of Wikipedia's structure and is not a problem per se. Pascal.Tesson (talk) 19:34, 9 August 2009 (UTC)[reply]

It's an outright lie to say that "[t]here has been no rationale given" for deletion. You may not agree with that rationale, but it is given in the nomination. They are not notable independent of the cases bearing their names, and we should not have articles about non-notable subjects. Policy reflects that common-sense judgment, both generally (the purpose of WP:N and its derivatives is to define circumstances for inclusion; its mere existence accordingly demonstrates that exclusion is the default condition) and specifically (SINGLEEVENT). As Uncle G said above, "we don't try to shoe-horn every subject in the world into individual biographies of the people involved in the subject, making those biographies one-sided and incomplete accounts of the actual overall subject, is one principle that underlies the BLP1E policy, and it is a principle that is not by its nature restricted to merely living people." He's right.- Simon Dodd { U·T·C·WP:LAW } 19:58, 9 August 2009 (UTC)[reply]

I'm saying there has been no rationale given for the removal of well-documented biographical information about Miranda from the encyclopedia. Miranda's life after the case would be out of place in the already very long article on the case. So if you delete Ernesto Miranda, that biographical information simply vanishes and you have not indicated why that net loss is a good idea. Pascal.Tesson (talk) 20:38, 9 August 2009 (UTC)[reply]

• Speedy keep Borderline pointy nomination based on a misinterpretation of WP:SINGLEEVENT (see here for the origin of the nomination). The policy says among other things that "if the event is highly significant, and the individual's role within it is a large one, a separate article is generally appropriate". Surely Miranda's role is significant. Biographical details of Miranda's life after Miranda v. Arizona would obviously be out of place in the article about the case. Pascal.Tesson (talk) 18:34, 7 August 2009 (UTC)[reply]
• Keep both. A significant number of readers will be interested in the "human side" of these landmark cases, so the information about the defendants should be available on Wikipedia; but a significant number of readers will want to know only about the legal issues, so the article about the case should omit such biographical detail. A standalone article is the best way to present the information. JamesMLane t c 20:23, 7 August 2009 (UTC)[reply]
  • Comment. I've edited each article to add information about the retrial that followed the Supreme Court decision setting aside the initial conviction. (Miranda was convicted again, but Gideon was acquitted.) This information will be of interest to many readers but would have no place in the article about the Supreme Court decision. JamesMLane t c 21:00, 7 August 2009 (UTC)[reply]
• Keep both. These people have become namesakes to such important law cases that I think there's a high likelihood of readers wanting to know more biographical detail about them that would be off-topic for the articles on the cases themselves. And there's plenty of reliable sourcing. I don't see why we can't keep separate articles on the people and the cases. As for WP:BIO1E, I think the line that "if the event is highly significant, and the individual's role within it is a large one, a separate article is generally appropriate" fits these two cases. —David Eppstein (talk) 21:56, 12 August 2009 (UTC)[reply]

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.