Wikipedia:Articles for deletion/People v. Sattlekau

:{{la|People v. Sattlekau}} – (View AfDView log{{int:dot-separator}} [https://tools.wmflabs.org/jackbot/snottywong/cgi-bin/votecounter.cgi?page=Wikipedia:Articles_for_deletion/People_v._Sattlekau Stats])

:({{Find sources AFD|People v. Sattlekau}})

Does not appear to pass WP:GNG. This case is not from the highest court in the jurisdiction (which would be the Court of Appeals), and doesn't appear to be subject to much secondary source coverage. Brianga (talk) 18:27, 22 November 2016 (UTC)

:Note: This debate has been included in the list of Law-related deletion discussions. Shawn in Montreal (talk) 19:43, 22 November 2016 (UTC)

:Note: This debate has been included in the list of New York-related deletion discussions. Shawn in Montreal (talk) 19:43, 22 November 2016 (UTC)

:Note: This debate has been included in the list of History-related deletion discussions. Shawn in Montreal (talk) 19:44, 22 November 2016 (UTC)

::Brianga, I added two more RS sources to establish WP:N. Specific to Brianga's other comments - being a case "from the highest court in the jurisdiction" (or not), is not relevant to establishing significant coverage in reliable secondary sources. Legal case textbooks "participate in the classic pedagogical tradition of relying on appellate decisions in actual cases to explicate the doctrines and policy dilemmas of the criminal law" (Robert Weisberg) So a case can be notable because it is widely read as the illustrative case. Furthermore, they become notable as sources of when they are used as sources, such as when cited in other cawsses. Also, the WP:N criteria is "significant", not "much" - it is "significant". This case is an entire chapter (the entire Fraud chapter) of the case textbook used by Stanford Law School (and other law schools) for decades. As per previous consensus, that is significant coverage. MBUSHIstory (talk) 18:53, 29 November 2016 (UTC)

• Delete. Per Westlaw, this case has only been cited 6 times in 100 years. Its inclusion in a casebook does not demonstrate notability. agtx 20:48, 22 November 2016 (UTC)

::* User:Agtx, I added two sources to establish WP:N, and generally commented below. What is the link for your Westlaw search (especially as there are multiple spellings - see comment below by Smmurphy)? Did the Westlaw search turn up the three sources that are now in the article? Six secondary sources may in itself establish WP:N. Also, a Westlaw search is not a required criteria to establish WP:N, although it would add to the significance of coverage. Significant coverage (an entire chapter in a widely distributed and used textbook) in a reliable secondary source is a criteria.

• Delete {{u|MBUSHIstory}} has been making a bunch of articles just taking stuff out of their textbook. None of these subjects is notable and most rely on a single source. Chris Troutman (talk) 19:26, 23 November 2016 (UTC)

:::* I added two sources as to why its notable, in addition to commenting below. User:Chris troutman wrote an article on The Raising of Lazarus (Rembrandt), which is one of my three favorite paintings in Los Angeles (the other two are Rembrandts at the Getty). These must be seen in person to see the linen of the shroud, and to let your eyes adjust to the dark (there are minutely detailed objects in what looks black in an art book or computer screen - same goes for the other two at the Getty, and more!).MBUSHIstory (talk) 18:29, 29 November 2016 (UTC)

• DeleteWeak keep - I agree that notability is not shown here and not easily verifiable. I'm sure lots of stuff in Kaplan, Weisberg, and Binder would make notable improvements to wikipedia, but I don't see that this article does. The defendant, whose full name I think is Ernest Paul Sattlekau (or Sattelkau or Sattlekan or...) may be notable, there seems to be a bit of coverage about him, but my guess is not. Smmurphy^(Talk) 16:39, 28 November 2016 (UTC)

• Keep - I added two more reliable secondary sources, which now clearly establishes WP:N. However, the following points from previous similar discussions should be reiterated as to one using one RS, when that RS is a major textbook used in major law schoools for decades.

:* A case textbook published by a major publisher, written by notable law professors, is a reliable secondary source.

:* Being an entire chapter in a case textbook (as is Sattlekau), used by major law schools (Stanford, Harvard, Yale, etc.), read by hundreds (or thousands) of law students each year, is significant coverage.

:* (Additionally, the fact that three of the most famous criminal law professors in the US found the case to be so notable that they made their entire fraud chapter about it, is objective evidence of those experts' opinion of the notability of the case.)

:We already had this exact same discussion on these two points, many times, for numerous other articles about cases. These discussions were posted at Wikiproject Law, not just at a meta-Wiki law-sorting forums (and nonrelevant history and New York sorting forum pages - this is an article about a textbook case, not a history article, and not an article about New York or notable New Yorkers). I ask that those editors' consensus comments be taken into account in this discussion. It makes no sense to keep revisiting this exact same discussion on which there is previous lack of consensus to delete. These are literally textbook cases.

::* User:Smmurphy writes, "Ernest Paul Sattlekau (or Sattelkau or Sattlekan or...) may be notable, there seems to be a bit of coverage about him". This is not an article about the person Sattlekau. It is an article about the case, Sattlekau, which is illustrative of a principle as to the elements of false pretense, especially as to the change in legal policy as to intentions and promises meeting these conditions in the same way as a material fact.

:* If editors have to spend time re-arguing the same points as above (and in previous discussions), over and again, about the most cases so basic that they are first year textbook cases, they will simply stop editing altogether, and Wiki will continue to forever be the very poor encyclopedia as to legal articles that it currently is. MBUSHIstory (talk) 16:18, 29 November 2016 (UTC)

:::Generally, editors do have to re-argue points at AfD, and given there was no consensus at Wikipedia:Notability (law), I don't see clear guidance from WP:Law here. Looking through the archives of Wikipedia talk:WikiProject Law, I find: Wikipedia talk:WikiProject Law/Archive 9#Notability of cases and doctrines from January of 2009, is that the discussion you are talking about? I don't see a clear consensus there in favor of notability given publication of a case in a casebook and it isn't clear this subject passes {{ping|bd2412}}'s test. That leaves GNG, which requires multiple independent sources. Both of the casebooks covering this case are written by Guyora Binder, and thus not terribly independent, although they are published by different editors. In any case, I'm happy to change my !vote if more notability were shown. For instance, has the US Supreme court cited the case? Have casebooks not written by Binder discussed the case in any depth? How much discussion is/was there in newspapers about the case? Smmurphy^(Talk) 17:23, 29 November 2016 (UTC)

::::User:Smmurphy, sorry, I should have provided at least one link if I was going to refer to past discussions. [https://en.wikipedia.org/wiki/Wikipedia:Articles_for_deletion/State_v._Leidholm Here] is one example of a recent discussion. I am adding the link I omitted above Smmurphy commented Once I pointed out that that case was an entire chapter in a major law school text book, used for decades, is significant secondary source coverage. The selection of a case by three famous law professors means that they consider the case notable. The Supreme Court did not hear the case, to my knowledge. The case caused a change in the law, as in the third RS I cited. MBUSHIstory (talk) 17:33, 29 November 2016 (UTC)

:::::I see. In the closing of that debate, the closing admin noted, "No prejudice against individually nominating some of the weaker ones if someone wants to take a closer look", indicating that their wasn't a general consensus established. If the page were not an orphan (and thus I could see how it fit into the greater fabric of law and history on wikipedia), that would be another point I would consider. Perhaps someone else from WP:Law can chime in? In the meantime, looking up the other two authors, I think they are clear experts and have struck/changed my vote. Binder's discussion in [https://books.google.com/books?id=wDdnDAAAQBAJ&lpg=PA407&dq=%22People%20v.%20Sattlekau%22&pg=PA252#v=onepage&q=%22People%20v.%20Sattlekau%22&f=false] is in depth enough, I think. Smmurphy^(Talk) 18:00, 29 November 2016 (UTC)

• Keep - inclusion in a major casebook for law students does indicate notability, but does not make it automatically notable. Looking deeper, it seems to be a precedent even if it's not been widely cited. Bearian (talk) 19:36, 29 November 2016 (UTC)
• Strong keep. We routinely keep precedent-setting cases like this. Furthermore, the case did, in fact, receive a fair bit of coverage in contemporaneous publications. See, for example:21 {{smallcaps|New York Criminal Reports. Reports of Cases Decided in All the Courts of the State of New York. Together with Leading Cases from Other Jurisdictions Involving Questions of Law and Practice. With Notes and References}} 579, 630 (1884-1925) (discussion of the case's holding and significance).11 {{smallcaps|Bench & B. o.s.}} 62, 70 (1907) (same).

104 {{smallcaps|The New York Supplement}} 1153, 1228 (1888-1922) (same).. The discussion about this case in those sources is sufficient to confer notability per WP:GNG. -- Notecardforfree (talk) 19:59, 29 November 2016 (UTC)

{{reflist talk}}

• Comment - [https://www.newspapers.com/search/#query=%22ernest+paul%22&dr_year=1906-1907&p_place=NY Here is a link to 11 New York Times stories] on this case. This is significant coverage in a reliable mainstream media source. (Thanks to User:Smmurphy for researching this). MBUSHIstory (talk) 20:44, 29 November 2016 (UTC)

::Note/correction, that is nine NY Times stories, two from the NY Sun. Many of the stories are copies of each other, and a few are routine mentions of the defendant being in court. That said, my favorite headline is: WOMAN PERSONAL VICTIM HAS HER DAY IN COURT; Appears Against Paul, Who, She Says, Took Her $1,000. HE ADVERTISED TOO OFTEN, The Second Time Rosa Kaiser Awaited Him with Pink Roses and a Detective [http://query.nytimes.com/gst/abstract.html?res=9E07E4D91F3EE733A2575BC0A96F9C946797D6CF&legacy=true] (nb, the defendant, Ernest Paul Sattlekau, called himself "Ernest Paul"). Smmurphy^(Talk) 20:47, 29 November 2016 (UTC)

{{clear}}

: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.