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Talk:Lozman v. City of Riviera Beach (2018)

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Did you know nomination

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The following is an archived discussion of the DYK nomination of the article below. Please do not modify this page. Subsequent comments should be made on the appropriate discussion page (such as this nomination's talk page, the article's talk page or Wikipedia talk:Did you know), unless there is consensus to re-open the discussion at this page. No further edits should be made to this page.

The result was: promoted by Theleekycauldron (talk) 02:42, 2 May 2022 (UTC)[reply]

( Comment or view )
( Article history links:
)
Fane Lozman's arrest in 2006
  • ... that "That Certain Unnamed Gray, Two-Story Vessel Approximately Fifty-Seven Feet in Length" took Fane Lozman to the US Supreme Court once, and an allegedly retaliatory arrest (pictured) took him there again? Source: Jesse D. H. Snyder, What Fane Lozman Can Teach Us About Free Speech, 19 Wyo. L. Rev. 419 (2019).
    • ALT1: ... that Fane Lozman, a "persistent gadfly", took Riviera Beach to the US Supreme Court once in 2013 for seizing his floating home and again in 2018 for arresting him (pictured), and won both times? Source: see above; also "persistent gadfly" per NYT
    • Comment: 2013 one was mainspaced in the past 7 days. 2018 one was 5X'd in the past 7 days. I'd like to do at least some work on the Lozman article in the near future, so it might make sense to hold this for a bit; but submitting now, now that these two are both in presentable states.

Moved to mainspace by Tamzin (talk). Self-nominated at 22:04, 11 April 2022 (UTC).[reply]

  •  Reviewing... – Muboshgu (talk) 15:35, 22 April 2022 (UTC)[reply]
  • Both articles are DYK eligible, one as a userspace draft moved to mainspace and the other as a 5x expansion. Lozman's article is too long for a 5x expansion, but could be a GA DYK in the future with work. Both articles are long and sourced throughout, with at least one citation per paragraph. AGF on the court filings used as inline references. They appear to be written neutrally. One minor issue that I won't hold up approval for is The case was noted for in the first sentence of the second paragraph of the 2013 article lead, please change that per MOS:NOTED. ALT0 reads a little clumsy to me, and is also slightly above the max 200 characters. I prefer ALT1. The video is tagged as PD based on Florida statutes. User has one DYK credit, so this nom is exempt from QPQ review requirement. – Muboshgu (talk) 15:46, 22 April 2022 (UTC)[reply]
    @Muboshgu: Thanks. I thought that MOS:NOTED applied to "noted that"-type constructions? To me "X was noted for" is shorthand for "observers took note of X for"... but I can switch to that expanded form if you'd like. Also, is ALT0 over the max? The submit script had it at 198 I think. I ask only because I think including the rather silly "name" of the not-vessel makes for a hookier hook. But ALT1 is definitely fine too. As to Lozman's article, yeah, I'd like to get that to GA at some point, but don't think I have the time now, sadly, so best to go ahead. If I do get some burst of energy to do that before this is promoted, I'll drop a note here and maybe we can work something out. Also, one more note: It was pointed out on the 2013 case's talk page that a picture of the floating home would help with the article, and I agree. Sadly, the picture used in the SCOTUS decision is unclear as to its provenance, and since SCOTUS has absolutely immunity from lawsuits there's no reason to think it's public domain or freely licensed. I reached out to Lozman in January and he agreed in principle to license some photos of it compatibly, but didn't reply to my most recent email about sorting that out... I'll give him a nudge, and hopefully we can manage that before this is promoted, but I guess we'll have to see. -- Tamzin[cetacean needed] (she/they) 20:33, 22 April 2022 (UTC)[reply]

GA Review

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Passed. MaxnaCarta (talk) 04:00, 11 November 2022 (UTC)[reply]

The following discussion is closed. Please do not modify it. Subsequent comments should be made on the appropriate discussion page. No further edits should be made to this discussion.

GA toolbox
Reviewing
This review is transcluded from Talk:Lozman v. City of Riviera Beach (2018)/GA1. The edit link for this section can be used to add comments to the review.

Reviewer: MaxnaCarta (talk · contribs) 09:09, 10 November 2022 (UTC)[reply]

Talk

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Hi @Tamzin:, nice to meet you. I actually was reading this case out of pure interest and observed it was a GA nominee. I am a practising lawyer in Australia and have reviewed one law related GA nom and have one GA myself. Just introducing myself as we have not previously communicated directly. Hopefully you feel I can do a good job reviewing your GA nom. I am a relaxed reviewer, I personally feel. I apply a rather broad interpretation to the GA criteria. I do not feel a GA article needs to be perfect but rather just...good! Having read your article, this is one that I think will easily pass. Just a few initial issues to discuss before I commence drafting the review template.

Please see issues. Let me know in the comment part if you believe this is a fair/accurate pickup. If so, please fix and let me know when done. If not, please tell me why it is not a good pickup and let's chat! Thanks and look forward to working with you. MaxnaCarta (talk) 09:24, 10 November 2022 (UTC)[reply]

Hi, MaxnaCarta! Think we've interacted in passing before, but never at length, so nice to formally meet you, and thanks for taking this on. Would be cool to get my first GA the same month as my ten-year anniversary here. (By the way, if you didn't know, adding a ping to an already-posted message doesn't ping someone.)
This is a kind of amusing situation for me, reading through your comments, as IRL I'm currently freelance copy-editing a book, so now I get a little taste of being on the other side of that equation. :D All of your comments so far seem reasonable, and I've replied to a few of the easy ones. I likewise look forward to working with you. -- Tamzin[cetacean needed] (she|they|xe) 10:08, 10 November 2022 (UTC)[reply]
Hi @Tamzin, thank you! I will not deny the biggest learning curve here has been learning to use code. I am somewhat successful but not really. I think we are probably sameish age, but my skills feel quite old school compared to some here. Please see resolved comments. I am now drafting the review. If any issues, I'll let you know, but I believe this will be passed by the end of today unless I come across something unexpected. MaxnaCarta (talk) 03:19, 11 November 2022 (UTC)[reply]
Oh and @Tamzin? I know that there have been previous cases, but I do not think we need to stipulate the year in the page title. Most cases that reach the supreme/highest court of the land in any country have had prior litigation history, and it is not common practice to include the year in the page title. Not a barrier to GA passing - but I think we should remove the year. MaxnaCarta (talk) 03:27, 11 November 2022 (UTC)[reply]

Initial issues

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  • Issue: First line of text, why is there an ____? Is this some part of U.S. referencing? Or does it need to be removed?
  • Comment: That's standard for a Supreme Court opinion that is yet to be published in the U.S. Reports. SCOTUS commits to a volume at time of decision, but not to a page number. -- Tamzin[cetacean needed] (she|they|xe) 10:03, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickYI suspected there was a reason for this.



  • Issue: "In the 1977 case of Mt. Healthy City School District Board of Education v. Doyle, the Supreme Court established a standard of but-for causation for claims of official retaliation against speech": this needs or would be better with a secondary reference. The next sentence is properly referenced in the same way this one could be.
  • Comment: The Koerner cite is meant to apply to both preceding sentences, with the two primaries in there for convenience and to briefly describe the holdings, Bluebook-style. If you think it would be better to duplicate the Koerner cite at the end of the first sentence too, I'm fine with that; six of one, half a dozen of the other, to me. -- Tamzin[cetacean needed] (she|they|xe) 10:03, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickY No worries. May come up again at Featured, but not a barrier to passing GA.




  • Issue: "Lozman then sued Riviera Beach pro se under 42 U.S.C. § 1983" - interesting, we merely refer to this as self-representation here in oz. Never heard the term pro se before. No objection to this staying, but too technical for the average reader? I know it's correct terminology, but I would not say "in her ratio decidendi, Ginsberg was a boss". While true, could we not say "in her reasons for her decision"? I am not a fan of latin. You may disagree however, not a barrier to passing. Same with "(assumed arguendo to exist)"
  • Comment: Yeah, arguendo is too technical. Looking through Google News, pro se definitely sees a fair amount of usage in non-technical publications, but it appears to be the minority approach. I'll reword. -- Tamzin[cetacean needed] (she|they|xe) 10:03, 10 November 2022 (UTC)[reply]
     Reworded -- Tamzin[cetacean needed] (she|they|xe) 12:27, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickY



  • Issue: Please capitalise Court. When referring to the Supreme Court of the United States even in part, the C must be capitalised. See San Francisco Bar Association practice note here.
  • Comment: This seems inconsistent with MOS:INSTITUTIONS. I realize I'm capitalizing "City Council", but I think generally legislative chambers' names are treated as proper nouns, e.g. "the House" or "the Senate". But I would think "the Court" would be generic and thus it should be lowercased. -- Tamzin[cetacean needed] (she|they|xe) 13:09, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickY - Given this is an encyclopaedia and not a court document, our guidelines take priority.


  • Issue: The following is a long sentence. Justice Clarence Thomas, in a solo dissent, wrote that plaintiffs should categorically have to "plead and prove a lack of probable cause as an element of a First Amendment retaliatory-arrest claim" and criticized the majority for "leaving in place the decades-long disagreement among the federal courts". I would write: Justice Clarence Thomas, in a solo dissent, wrote that plaintiffs should categorically have to "plead and prove a lack of probable cause as an element of a First Amendment retaliatory-arrest claim". Thomas criticized the majority for "leaving in place the decades-long disagreement among the federal courts".
  • Comment:  Changed, although I used "he" rather than "Thomas" in the second sentence. -- Tamzin[cetacean needed] (she|they|xe) 13:09, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickY Thanks! I agree with your approach, consistency is required.


  • Issue: "Heidi Kitrosser of SCOTUSblog compared its limited scope to the Onion headline "Supreme Court Issues Landmark 'It Depends' Ruling" - you cite the onion article, but where is the Kitrosser citation?
  • Comment: In the same ref, With facts like these, supra; that appeared to be the correct way, in Bluebook, to indicate that I'm reusing a previously-cited source, but with a "citing..." not in the original. -- Tamzin[cetacean needed] (she|they|xe) 13:09, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickY Fair explanation.


  • Issue: "First Amendment Foundation filed a brief amicus curiae" ajdfdaksjfh! Why more latin? ^_^
  • Comment: This one really is pretty common in the U.S., even in non-technical publications. I happen to have recently written an article mostly about an amicus brief (which, purely coincidentally actually, turned out to have a tie-in back to this one!), and looking at the general-audience-oriented cites in that, WaPo says "amicus brief" on first reference and defines it several paragraphs later, NPR say "amicus brief" and never defines it, NYT says "friend-of-the-court", and AP just says "brief". So 2 out of 4, and the Times does say "amicus" fairly often, just apparently not in that article. So I think this bit of Latin is better kept. -- Tamzin[cetacean needed] (she|they|xe) 13:09, 10 November 2022 (UTC)[reply]
  • Addressed? Green tickY - Look, I personally would avoid it. Perhaps at FA level, it may be something to consider discussing further. However for the purposes of GA, this is no barrier and I consider both our positions to be adequate. Given this "your" (I know it does not belong to anyone, but you did most of the work is what i mean) article instead of my own submission, I see no reason my view should take precedence and so there is no reason it should change for a GA review.

Review section

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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. The prose is clear, and easily understood by a wide audience. The prose exceeds the standards of GA criteria. The prose is highly engaging and is in my view, close or already to a professional standard. I would have phrased certain sentences differently, however my preferred method is not necessarily any better than what is existing. Spelling and grammar is excellent, I detected no typo's. Significant effort and skill have been invested into the prose.
1b. it complies with the Manual of Style guidelines for lead sections, layout, words to watch, fiction, and list incorporation. The article contains a useful, well written lead. The lead is concise, but complete in its summary of the topic. Further detail is expanded in later sections. No important facts are missing from the lead, and new facts not found in the remainder of the article are within the lead. All required MOS guidelines have been complied with, however I was not able to immediately detect any examples of non-core requirements being disregarded. Compliance with MOS is excellent.
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. Referencing was used correctly. Any issues have been addressed.
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). A significant issue I faced in my first GA review (mine too was a legal case) was that I relied on the case citation itself as a citation. This was not the case here. The case was barely referenced, instead, sources of the highest quality were used. Journal articles and other scholarly commentary from peer-reviewed work was used.
2c. it contains no original research. As above. The author has gone to great effort in citing all required sentences. Quality referencing is throughout. References 15, 18, 23, and 28 were checked and fine.
2d. it contains no copyright violations or plagiarism. No issues detected.
3. Broad in its coverage:
3a. it addresses the main aspects of the topic. This article is succinct.
3b. it stays focused on the topic without going into unnecessary detail (see summary style). Great length. More commentary may be needed, and further review of available literature before it can progress to FA/A review (if that is what you ever aim for) however few casual readers will be left wanting for additional detail. This article is complete without being verbose or straying off topic.
4. Neutral: it represents viewpoints fairly and without editorial bias, giving due weight to each. Presents the facts in a neutral way and discusses some literature without inappropriate synthesis of sources.
5. Stable: it does not change significantly from day to day because of an ongoing edit war or content dispute. So much stability. So few edit wars. Law articles tend to miss out on the drama, as has happened with this one. Contrarily to edit warring, the history shows a list of collaboration between editors.
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. Excellent use of media. The video footage is helpful.
6b. media are relevant to the topic, and have suitable captions. Good captions.
7. Overall assessment. This article easily meets basic editorial standards. I feel this article is without question one satisfies GA criteria, and is well on its way, if not already there, to meeting A or FA criteria. Overall, this work is an example of a very good article, close to being one of the best I have come across in the Law Project. It is of high and reliable quality with outstanding style compliance. Appropriate media has been included. Perhaps for any future review, the article needs a little expansion. However that being said, I consider article relatively broad, and near complete in its coverage of relevant facts.



The discussion above is closed. Please do not modify it. Subsequent comments should be made on the appropriate discussion page. No further edits should be made to this discussion.

Title

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@MaxnaCarta: Regarding your comment transcluded above, removing the date from this title would imply it's primary over Lozman v. City of Riviera Beach (2013), and I'm not sure that's the case. The 2018 case is higher-profile, but the 2013 is probably more impactful in the end, since it settled (for some value of "settled") a longstanding question in admiralty law, whereas the lasting impact of the 2018 case is essentially "being the one between Reichle and Nieves" and establishing an exception to Hartman that it remains unclear whether anyone will ever successfully invoke. (Tangentially, currently Lozman v. City of Riviera Beach is a set index article, and I've been thinking about expanding it [partly forking from Fane Lozman, which at this point is a bit overly focused on the cases] so that it's essentially a history of all litigation between the two parties.) -- Tamzin[cetacean needed] (she|they|xe) 06:36, 11 November 2022 (UTC)[reply]

Makes sense @Tamzin MaxnaCarta (talk) 06:45, 11 November 2022 (UTC)[reply]
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