Wikipedia:Peer review/Salazar v. Ramah Navajo Chapter/archive1

Salazar v. Ramah Navajo Chapter

This peer review discussion has been closed.
I've listed this article for peer review because I plan on taking the article to FA.

Thanks, GregJackP Boomer! 19:16, 4 January 2014 (UTC)

Pretty solid. A few things you might want to look at.

1. The text on the map is too small to read, and (more important to me) there's no key indicating what the colors mean. This has nothing at all to do with the gravamen of the article, but it is a little distracting.
2. The map gives the impression that Ramah is not in the "far eastern part of the Navajo Nation", the reservations (?) in Oklahoma have that distinction.
3. "The Ramah Chapter has learned to fight for its rights" comes across as editorializing.
4. If footnote 1 stays, perhaps add a year to Ramah Navajo School Board to give it a bit more context.
5. Direct cost and Indirect costs are terms of art that need to be explained. There is an article for indirect costs, but I don't know enough to know if it's relevant here.
6. pro rata should be italicized throughout.
7. This is probably my unfamiliarity with the topic, but I don't understand what is being conveyed by this sentence: "When there were shortfalls in the amounts paid by BIA to the tribe, services to tribal members were usually cut in order to pay the tribe's indirect costs." A specific example would be really helpful here: program x had $y direct costs and $z indirect costs, but the BIA only allocated $w, so thus and such services were cut.
8. "Indian tribes are treated differently--the court noted" Should that be an mdash: "—" ?
9. "not a case of first impression" Perhaps link to First impression (law).
10. "Sotomayor stated that although the situation that Congress placed the BIA in is frustrating," Sentence fragment.
11. " If the appropriation exceeds the amount of the individual contract, then the government is bound to honor the contract." Is this correct? I would think that the problem only exists if the contract exceeds the appropriation.
12. Which justices joined the majority and which joined the dissent? (Ah, I see that's in the infobox. Perhaps in the text as well?)
13. Perhaps a summing-up sentence stating what the case requires in terms of direct and indirect costs.
14. Looking at both scotusblog and Indian Country Today summaries of the case, the idea of "contract support costs" leads off the discussion. That term doesn't appear in the article until the second appeal to the circuit court. Should this be discussed up in the lead as well? (The "plain English summary" at scotusblog is particularly good; I'm not sure how something like it might be included here, though.)
15. "on July 20, 2012 on the issue." Perhaps "to discuss the issue"?
16. I'd like to see more information on the aftermath, but I don't know if the sources are out there or not.

Overall, nice work! Best of luck to you at FA! Catherine Quotidian (talk) 04:18, 8 January 2014 (UTC)

Addressing:

• The text on the map is too small to read, and (more important to me) there's no key indicating what the colors mean. This has nothing at all to do with the gravamen of the article, but it is a little distracting.

Added explanation that Navajo reservations are in orange. The other colors are all Apache tribes. GregJackP Boomer! 12:04, 8 January 2014 (UTC)

• The map gives the impression that Ramah is not in the "far eastern part of the Navajo Nation", the reservations (?) in Oklahoma have that distinction.

See above. GregJackP Boomer! 12:04, 8 January 2014 (UTC)

• "The Ramah Chapter has learned to fight for its rights" comes across as editorializing.

Fixed. GregJackP Boomer! 12:04, 8 January 2014 (UTC)

• If footnote 1 stays, perhaps add a year to Ramah Navajo School Board to give it a bit more context.

Fixed. GregJackP Boomer! 12:04, 8 January 2014 (UTC)

• Direct cost and Indirect costs are terms of art that need to be explained. There is an article for indirect costs, but I don't know enough to know if it's relevant here.

Linked both. GregJackP Boomer! 12:17, 8 January 2014 (UTC)

• pro rata should be italicized throughout.

Fixed. GregJackP Boomer! 12:17, 8 January 2014 (UTC)

• This is probably my unfamiliarity with the topic, but I don't understand what is being conveyed by this sentence: "When there were shortfalls in the amounts paid by BIA to the tribe, services to tribal members were usually cut in order to pay the tribe's indirect costs." A specific example would be really helpful here: program x had $y direct costs and $z indirect costs, but the BIA only allocated $w, so thus and such services were cut.

I don't know that I can find a sourced example, but I'll look. Reworded for now. GregJackP Boomer! 16:11, 11 January 2014 (UTC)

• "Indian tribes are treated differently--the court noted" Should that be an mdash: "—" ?

Fixed. GregJackP Boomer! 12:17, 8 January 2014 (UTC)

• "not a case of first impression" Perhaps link to First impression (law).

Fixed. GregJackP Boomer! 12:17, 8 January 2014 (UTC)

• "Sotomayor stated that although the situation that Congress placed the BIA in is frustrating," Sentence fragment.

Fixed. GregJackP Boomer! 16:41, 11 January 2014 (UTC)

• " If the appropriation exceeds the amount of the individual contract, then the government is bound to honor the contract." Is this correct? I would think that the problem only exists if the contract exceeds the appropriation.

No, that's correct. There are over 500 tribes and numerous contracts. What the Court said was that if the amount of the appropriation was larger than any single contract, the government had to pay the full value of the contract. The problem exists because the amount needed to pay all of the contract exceeds the amount of the appropriation (by a large amount). GregJackP Boomer! 13:36, 9 January 2014 (UTC)

• Which justices joined the majority and which joined the dissent? (Ah, I see that's in the infobox. Perhaps in the text as well?)

Done. GregJackP Boomer! 16:41, 11 January 2014 (UTC)

• Perhaps a summing-up sentence stating what the case requires in terms of direct and indirect costs.

I'm not clear on what you are suggesting here. GregJackP Boomer! 16:41, 11 January 2014 (UTC)

• Looking at both scotusblog and Indian Country Today summaries of the case, the idea of "contract support costs" leads off the discussion. That term doesn't appear in the article until the second appeal to the circuit court. Should this be discussed up in the lead as well? (The "plain English summary" at scotusblog is particularly good; I'm not sure how something like it might be included here, though.)
• "on July 20, 2012 on the issue." Perhaps "to discuss the issue"?

Done. GregJackP Boomer! 16:41, 11 January 2014 (UTC)

• I'd like to see more information on the aftermath, but I don't know if the sources are out there or not.

Comments by Wehwalt. Nice job. My usual quibbles

• "The Ramah Chapter, due to its location, is the only Navajo Chapter with its own Bureau of Indian Affairs (BIA) agency and a semi-autonomous government." What about the location is significant?

The Chapter was autonomous for a number of years before rejoining the Navajo Nation, and it is geographically separated from the main reservation. GregJackP Boomer! 16:50, 11 January 2014 (UTC)

• "The contracts required two parts, first the direct cost of the program being administered by the tribe, and second, indirect costs of administering the program, subject to funds being appropriated by Congress." I'm not quite clear what these "parts" are.
• "Aid to Tribal Government" why is this capped? If it is the name of a program, you might want to signal the reader, either by adding something like "program" or perhaps adding an abbreviation. Just to let people know it's a proper noun.
• "It is unclear to me where the sentences prior to text note 6 are sourced to.
• "was an issue on" perhaps "was an issue of"
• The one sentence statement at the start of "Supreme Court" could, I believe, correctly be moved into the previous section. I think the date of cert being granted could be usefully included as well. Possibly also the date they filed for cert. Any orders of interest (that is, not granting live to file a brief amicus curiae?)
• " resolved in the tribes favor" needs an apostrophe. Pardon, I usually fix the small things myself but I'm doing this online and will go cut and paste my review in when I'm done.
• "Amicus curae briefs" Isn't it curiae?
• I think the year of the Leavitt decision should be added, perhaps in parens. If this is going to be used by law students, we're talking about people who aren't necessarily good with numbers.
• The image of Sotomayor is pushing the next section's heading right.
• " Sotomayor stated that although the situation that Congress placed the BIA in is frustrating,[fn 12] The " some modification needed here, I think
• I would eliminate one or the other uses of "court" in the following sentence.
• You should probably mention, in text, the court members who formed the majority, and those who joined the opinion of Roberts, C.J., dissenting
• "since Cherokee Nation did not have a similar restriction on reducing other payments." This needs to be better explained.

• Footnote 1. If part of it was about who got federal payments for Indians attending school, I think it would be a good thing to say so. As it is, they just sound mean and bigoted. Let's cut them a break if we can.

Very well done, not much to criticize considering the length.--Wehwalt (talk) 10:43, 9 January 2014 (UTC)

Addressing:

• "The Ramah Chapter, due to its location, is the only Navajo Chapter with its own Bureau of Indian Affairs (BIA) agency and a semi-autonomous government." What about the location is significant?

The location is a geographically separated from the rest of the tribe and the main reservation. GregJackP Boomer! 13:39, 9 January 2014 (UTC)

• "The contracts required two parts, first the direct cost of the program being administered by the tribe, and second, indirect costs of administering the program, subject to funds being appropriated by Congress." I'm not quite clear what these "parts" are.

Linked both direct and indirect costs (noted above). GregJackP Boomer! 16:53, 11 January 2014 (UTC)

• "Aid to Tribal Government" why is this capped? If it is the name of a program, you might want to signal the reader, either by adding something like "program" or perhaps adding an abbreviation. Just to let people know it's a proper noun.

Done. GregJackP Boomer! 16:53, 11 January 2014 (UTC)

• "It is unclear to me where the sentences prior to text note 6 are sourced to.
• "was an issue on" perhaps "was an issue of"
• The one sentence statement at the start of "Supreme Court" could, I believe, correctly be moved into the previous section. I think the date of cert being granted could be usefully included as well. Possibly also the date they filed for cert. Any orders of interest (that is, not granting live to file a brief amicus curiae?)
• " resolved in the tribes favor" needs an apostrophe. Pardon, I usually fix the small things myself but I'm doing this online and will go cut and paste my review in when I'm done.
• "Amicus curae briefs" Isn't it curiae?

Yup, fixed. GregJackP Boomer! 13:39, 9 January 2014 (UTC)

• I think the year of the Leavitt decision should be added, perhaps in parens. If this is going to be used by law students, we're talking about people who aren't necessarily good with numbers.
• The image of Sotomayor is pushing the next section's heading right.
• " Sotomayor stated that although the situation that Congress placed the BIA in is frustrating,[fn 12] The " some modification needed here, I think
• I would eliminate one or the other uses of "court" in the following sentence.
• You should probably mention, in text, the court members who formed the majority, and those who joined the opinion of Roberts, C.J., dissenting
• "since Cherokee Nation did not have a similar restriction on reducing other payments." This needs to be better explained.

• Footnote 1. If part of it was about who got federal payments for Indians attending school, I think it would be a good thing to say so. As it is, they just sound mean and bigoted. Let's cut them a break if we can.