Wikipedia:Articles for deletion/Nandor Vadas

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 Procedural close; please relist separately. NW (Talk) 20:20, 26 August 2009 (UTC)[reply]

Nandor Vadas

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non-notable person. He's a United States magistrate judge, an assistant/temporary district judge - not an automatically notable person, imo. As a matter of fact we're putting a proposal together for the notability of law/lawyers at the moment. Ironholds (talk) 01:56, 19 August 2009 (UTC)[reply]

While a lower level judicial officer, MJ Vadas is notable. He started a early settlement program for inmate settlement programs that has been adopted by all of the prisons in this District and some in the next district over. The amount of cases that this will clear from court calendars will save everyone a fortune.Geoff Plourde (talk) 02:42, 19 August 2009 (UTC)[reply]

Very nice. And do we have reliable, independent sources covering Mr Vadas in sufficient detail? Ironholds (talk) 02:45, 19 August 2009 (UTC)[reply]

In addition, I found at least 7 other entries for magistrate judges, most of which are similar to this one (e.g. David Nuffer) Also there is a Category:United States magistrate judges. Geoff Plourde (talk) 02:47, 19 August 2009 (UTC)[reply]

There is a press release by the US District Court (included in article), the Times-Standard, and he was mentioned in another publication, the Northcoast Journal. I need to search the archives though. Geoff Plourde (talk) 02:49, 19 August 2009 (UTC)[reply]

See WP:OTHERSTUFFEXISTS. The District Coourt release can't really be considered to be independent, considering the subject matter, the Times-Standard article is acceptable but local. Ironholds (talk) 02:55, 19 August 2009 (UTC)[reply]

Vadas prosecuted a case in the 9th Circuit, United States v. Gomez-Rodriguez Geoff Plourde (talk) 03:22, 19 August 2009 (UTC)[reply]

So he was an attorney in a case? I have to say you're grasping at straws here. I know several barristers who have acted in the House of Lords that isn't a claim to notability. Ironholds (talk) 04:11, 19 August 2009 (UTC)[reply]

Despite your concerns, I still believe that Vadas is notable for several reasons. I read the OTHERSTUFFEXISTS essay with great interest, but it really doesn't apply to this case. In your original filing here, you stated that the subject is only a temporary judge. By showing that other magistrate judges with similar experience have articles and that there is even a category for magistrate judges' articles, I was not implying that he is automatically notable, but pointing out an error in your reasoning. Also, I disagree with your assertion that he is just a temporary judge. Unlike British magistrates, US Magistrates are considered to be judicial officers with a broad jurisdiction. They don't just deal with traffic tickets and minor cases, but jury and bench trials on referral. Due to the scope of matters heard and government classification, magistrate judges are judges and should be treated as such. As regards sourcing, I have linked to the State Bar, the Court press release and two newspaper articles. The Court website also hosts opinions that Vadas has authored over the last several years. Additionally, Vadas started a successful ADR program and is a member of the Magistrate Judge Advisory Group. Geoff Plourde (talk) 06:43, 19 August 2009 (UTC)[reply]

I said assistant/temporary - assistant is the one that (currently) applies. As otherstuffexists shows, showing that er.. other stuff exists doesn't help. The fact that judicial decisions have been published is also irrelevant - they've been published by an associated judicial body, which is exactly what I'd expect. References: the press release is not independent, and is irrelevant. this does not give "significant" coverage - it mentions him in little more than a significant sentence. this is acceptable, although a local paper, and again, the State Bar site is completely irrelevant. If that was to be taken to be a reliable, independent reference covering him in significant details then every lawyer ever allowed to qualify in California would have an article. Ironholds (talk) 11:39, 19 August 2009 (UTC)[reply]

He does not qualify as a lawyer, but as a federal judicial officer and representative to the Judicial Conference. He is not an assistant judicial officer, but a judicial officer under Article I of the US Constitution. If this is not sufficient, then every other magistrate judge's article with similar instances needs to be deleted, and I will promptly act according to consensus here. Regardless of the independence of the press release, it is relevant as it lists his career and is prima facie proof of appointment. The Northcoast Journal articles establish the reasons why he left the district attorney's office. I do not understand your dislike of government websites, but the Bar website serves as proof of admission to the bar, disciplinary history, and academic background. Geoff Plourde (talk) 19:22, 19 August 2009 (UTC)[reply]

The press release isn't independent, no - so it doesn't pass WP:BIO. I do not have a dislike of government websites, but I don't feel the bar website is a valid reference as required under WP:BIO, because the bar website lists every attorney qualified to practice - it isn't evidence of notability. It would be like citing a note from Companies House which says that a company exists and is incorporated as evidence that the company is notable. Ironholds (talk) 19:26, 19 August 2009 (UTC)[reply]

I still disagree about the bar website, and I am not using it for notability, but as proof that he is a lawyer, the year he was admitted to the bar, and his educational background. While the press release may violate the letter of WP:BIO, I don't think it is contrary to its spirit, because it is a reliable source. I understand your concerns completely and am willing to agree to disagree on the notability of magistrate judges. Now as a fellow student of the law (Admission forthcoming in 10 or so years), I would like to ask that the same standard applied here be applied to other magistrate articles. Would it be possible to nominate all of them for deletion and joinder them to this case? Geoff Plourde (talk) 19:39, 19 August 2009 (UTC)[reply]

Certainly, feel free. I see the misunderstanding here - I was judging the bar site and the like on "do they count as the multiple independent, reliable etc etc sources required under WP:BIO" rather than "do they count as a WP:RS for the purpose of verifying facts within the article". Ironholds (talk) 19:47, 19 August 2009 (UTC)[reply]

I am attaching the above mentioned magistrates to this case because the issue of notability is applicable to all of them. Geoff Plourde (talk) 20:26, 19 August 2009 (UTC)[reply]

Delete All. They don't meet the WP:GNG. Not ready to consider all judges de facto notable without support of substantial coverage in reliable secondary sources. District Court judges maybe, but not Magistrates.--brew crewer (yada, yada) 21:03, 19 August 2009 (UTC)[reply]
Consider separately. I don't consider a Magistrate Judge to be inherently notable for occupying that position. It's appointed by the courts, limited in term (8 years, I think), and not subject to Senate confirmation. However, it's one thing to say that being a Magistrate Judge, per se, does not convey notability; and an entirely different thing to say that Magistrate Judges are per se not notable. Each of these individuals should be separately considered. For each, the fact that he is a Magistrate Judge is one factor to be considered in determining whether he is notable. Unless there is a consensus that holding a Magistrate Judge position inherently conveys notability (in which case all these articles should be kept), each needs to be separately considered. Positions like "Delete All" do not properly assess them on a case-by-case basis. TJRC (talk) 21:53, 19 August 2009 (UTC)[reply]
Speaking as someone who's assessed them all individually, delete all works fine. We're actually in the process of drafting a notability guideline on judges for Wikiproject:Law, although I doubt it'll be done before this AfD is. Ironholds (talk) 23:53, 19 August 2009 (UTC)[reply]

Completely agree with TJRC -- I only know of Alan Kay (judge). When I started that article I had assumed he was a US District Court Judge, like all the other judges making rulings on the Guantanamo habeas corpus petitions. I have added some details on Kay's rulings. He made some key rulings. Geo Swan (talk) 01:23, 20 August 2009 (UTC)[reply]
'It is Judge Robertson’s order on the terms of Hamdan’s confinement that is at issue, and in the ordinary situation, he would be the one to act on it. In an order issued early last month, the District Court said all disputes on “logistical issues, such as communications with or visits to clients and counsel,” for any of the detainees at Guantanamo who have court cases pending, are to be examined first by a magistrate judge, Alan Kay.'

Keep for Alan Kay -- Alan Kay made several key rulings in forcing the Department of Defense to allow Guantanamo captives access to their attorneys. He is notable. I haven't yet looked at the other guys. I think adding them to this {{afd}} was a mistake, because the individuals don't have enough in common. It was possibly disruptive enough that this {{afd}} should be speedy kept, and nominator(s) should initiate new {{afd}} -- one at a time. Geo Swan (talk) 14:10, 20 August 2009 (UTC)[reply]
Not getting ahead of yourself there somewhat? "examined first by a magistrate judge" means "he takes a look at the case" not "he deals with an entire trial related to gitmo people". In England and Wales we have a system where serious crimes are looked at first by a magistrate to check that, yes, it is worth sending it to the Crown Court. That doesn't mean that the magistrates who deal with that element of a noted case suddenly become notable. Ironholds (talk) 14:13, 20 August 2009 (UTC)[reply]
- No, I do not think I am getting ahead of myself. How close a look have you taken at the rulings Alan Kay made? His rulings were cited over and over again in Guantanamo captive habeas corpus petitions. Maybe you consider habeas corpus petitions trivial, beneath notice? Is so these ones are the exceptions. So far three, count-em, three of their habeas petitions have arrived at the SCOTUS. So, no, they aren't trivial. I remain concerned that you approved the adding of a bunch of individuals with little in common to your original nomination. I continue to see this as disruptive. And I would appreciate you responding to that concern. Geo Swan (talk) 14:28, 20 August 2009 (UTC)[reply]
Do me a favour and read WP:DISRUPTIVE. There's my response. Ironholds (talk) 14:29, 20 August 2009 (UTC)[reply]

Okay. I have read it. I suggest Geoff Ploude's addition of other individuals, because they too were magistrate judges could be seen as WP:POINTy. He was in favor of keeping Nandor Vadas, and didn't see why other magistrate judges shouldn't face deletion as well. You endorsed his addition, which, I suggest, also could be seen as WP:POINTy. I suggest that it could be considered that rather than challenging his addition of the other individuals you called his bluff. These individuals are all different. I suggest no one who wants to offer an informed opinion can do so in a single response that applies to all of these individuals. Geo Swan (talk) 14:59, 20 August 2009 (UTC)[reply]

While I would like to see Vadas kept, I believe that the point Ironholds raised (automatic notability of magistrate judges) deserves discussion in context. It is better to have one discussion in terms of all magistrate articles then to have the same discussion six or seven different times. Geoff Plourde (talk) 19:25, 20 August 2009 (UTC)[reply]

Note: This debate has been included in the list of Law-related deletion discussions. —Geo Swan (talk) 14:11, 20 August 2009 (UTC)[reply]

I am adding this discussion to the following two deletion sorting stubs because of the key role Alan Kay has played in the Guantanamo habeas petitions. Geo Swan (talk) 14:11, 20 August 2009 (UTC)[reply]

Note: This debate has been included in the list of Guantanamo Bay detainment camp-related deletion discussions. —Geo Swan (talk) 14:11, 20 August 2009 (UTC)[reply]
Note: This debate has been included in the list of Terrorism-related deletion discussions. —Geo Swan (talk) 14:11, 20 August 2009 (UTC)[reply]
Keep for John M. Facciola -- I know we are only supposed to express one keep, delete, merge opinion. But that doesn't work for me when the individuals have so little in common. So I am going to go through them one at at a time.
Still, it makes big news when the White House claims months of e-mails may have gone missing, and Facciola is the magistrate trying to sort out that case with the oversize name, Citizens for Responsibility and Ethics in Washington v. Executive Office of the President. Geo Swan (talk) 14:20, 20 August 2009 (UTC)[reply]
Keep for Paul Grimm -- I continue to be concerned over the disruptive nature of approving the adding of multiple individuals with little in common to an {{afd}} that was already in progress. According to one of the references Grimm found himself called upon to make a ruling in an area no previous judge had ever ruled on -- when should evidence in digital form be considered "authentic". IANAL, but won't this mean that all kinds of judges, including more senior judges, cite his ruling?
Under the Federal Rules of Evidence, a judge must determine whether a piece of electronic evidence is authentic and original, an issue no court had really touched on, even though digital evidence is easily manipulated. In looking at the potential electronic evidence in Lorraine, Grimm had to consider such fundamental questions as: What is a document? In a 52-page opinion, he found five distinct evidentiary issues one side must cross to prove whether electronic data should be admitted into evidence at trial or accepted as an exhibit (see “Grimm’s Issues of ESI”) Geo Swan (talk) 14:37, 20 August 2009 (UTC)[reply]

Automatic Notability

The following question forms the locus of this AfD and is an issue worthy of discussion. The result is applicable to each and every magistrate judge article, hence their nomination for deletion.

Does a U.S. Magistrate Judge, a federal judicial officer under the authority of Article I of the U.S. Constitution, automatically become notable by virtue of position?

Yes A MJ has the authority to hear all non felony cases on referral. Because of the amount of cases they hear, they form an integral part of the U.S. judiciary. In addition to arraignment and warrant functions, they can instruct juries, sentence offenders, and make binding orders. They are not just court clerks or temporary judges, regardless of fixed terms of appointment. The fact that they don't serve for life is moot, because state supreme court judges in the US serve for terms and are generally considered notable. Geoff Plourde (talk) 19:37, 20 August 2009 (UTC)[reply]

And? In the United Kingdom County Court judges can instruct juries, sentence offenders and make binding orders - Justices of the Peace can do the last two. They are hardly significant powers within the judiciary. Ironholds (talk) 02:57, 21 August 2009 (UTC)[reply]

Rural magistrates also have almost full judicial powers because of the expense of sending a matter to the District Court for trial. The only cases they won't hear are felony trials. Geoff Plourde (talk) 05:06, 21 August 2009 (UTC)[reply]

If Magistrate Judges are not explicitly exempted by having their notability challenged -- like heads of state and members of national legistlatures, then I don't think Nandar Paras, David Nuffer and Arlene Rosario Lindsay don't have sufficient references to merit an article of their own. If Magistrate Judges are explicitly exempted then this whole {{afd}} should be withdrawn. Alan Kay, John M. Facciola and Paul W. Grimm, IMO, would merit coverage whether Federal judges are all considered notable. I continue to believe amalgamating all these individuals in a single {{afd}} is a mistake, because they do not have enough in common. Geo Swan (talk) 00:50, 22 August 2009 (UTC)[reply]

@Geoff Plourde: "A MJ has the authority to hear all non felony cases on referral." No, an MJ has the authority to hear all petty offenses in referral; and misdemeanors only if the defendant agrees. "The fact that they don't serve for life is moot, because state supreme court judges in the US serve for terms and are generally considered notable." Well, "moot" means debatable, so I agree that it is moot in that sense. But more to the point, state supreme court judges are, well, supreme. In contrast, magistrate judges are, to use the constitutional word, inferior, which is pretty much the opposite of "supreme." TJRC (talk) 03:48, 22 August 2009 (UTC)[reply]

Actually, defendants don't necessarily have a choice. Where I live, all non felony matters are referred to the magistrate automatically and remain there. Geoff Plourde (talk) 02:02, 23 August 2009 (UTC)[reply]

Well, I don't know where you live; powers of magistrate judges may be different outside of the U.S. My observations are limited to the U.S., and my position in this discussion is limited to U.S. magistrate judges. In the U.S., other than for petty offenses, a magistrate judge can only try the case with consent of the defendant. See 18 USC 3401(b):

(b) Any person charged with a misdemeanor, other than a petty offense may elect, however, to be tried before a district judge for the district in which the offense was committed. The magistrate judge shall carefully explain to the defendant that he has a right to trial, judgment, and sentencing by a district judge and that he may have a right to trial by jury before a district judge or magistrate judge. The magistrate judge may not proceed to try the case unless the defendant, after such explanation, expressly consents to be tried before the magistrate judge and expressly and specifically waives trial, judgment, and sentencing by a district judge. Any such consent and waiver shall be made in writing or orally on the record.

TJRC (talk) 03:30, 23 August 2009 (UTC)[reply]

I live in California, and the local district classifies all misdemeanors as petty offenses. Geoff Plourde (talk) 05:51, 23 August 2009 (UTC)[reply]

I'm skeptical that that is correct. Petty defenses are defined by statute, see 18 USC 19, add'l info in § 3559 and § 3571; a petty offense is essentially one with less than a six-month term of imprisonment and a fine of less than $5000. This is a statute, not a rule, and nothing suggests that a local district may by rule modify the statute to remove a very clear protection afforded to defendants by Congress. Where are you getting your information? Which district are you referring to? (California has 4: Northern, Southern, Eastern and Central.) In any event, even if you were to be correct, this would simply mean that magistrate judges are the federal equivalent of a municipal judge in those state systems that have municipal courts; as opposed to being even less powerful than muni judges. In either event, the position itself does not merit per se notability. TJRC (talk) 19:48, 23 August 2009 (UTC)[reply]

Northern Geoff Plourde (talk) 23:30, 23 August 2009 (UTC)[reply]

There's nothing in the Northern District Local Criminal Rules that says anything like you claim. In fact, local rule 58.1, dealing with what cases a Magistrate Judge can hear, starts with "Subject to the limitation of 18 U.S.C. § 3401...", i.e., subject to the limitations including the portion quoted above that limits them to petty offenses unless the defendant consents. Where are you getting your information that this is not the case? Neither the United States Code nor the Northern District's local rules support what you're saying. According to both, the MJ's power to hear cases is lesser than that of a municipal judge in most states. TJRC (talk) 01:03, 24 August 2009 (UTC)[reply]

No. MJ is not a position that makes its occupant inherently notable.

An MJ has no power to try felonies. This is similar to a lowly municipal court judge in most states' systems.
An MJ has no power to try misdemeanors, other than petty offenses, except by the consent of the defendant. This is less than the power of the lowly municipal court judge.
An MJ is not an Article III judge position. It is an Article I judge position, stemming from Congress's power to constitute tribunals inferior to the Supreme Court.
As an Article I position, the judges are not lifetime appointees. They get eight-year terms. In fact, they're forced out when they're 70.
MJs are not appointed by the President. They're appointed by district court judges, who are the lowest level of Article III judges.
MJs are not subject to Senate confirmation; they are, in the terms of Article II, "inferior officers"
MJs do not need to be impeached to be removed from office. They can be removed if the Judicial Conference simply determines "that the services performed by his office are no longer needed." You don't need impeachment by the House of Representatives and a trial by the Senate; just a majority of the judges in the district.
MJs are federal judges only by coincidence of the word "judge" in the title, and are really no more "judges" than that guy who lost the pants lawsuit, who was an "administrative law judge." Heck, they weren't even called magistrate judges until 1968; for the first couple-hundred years of the U.S., they were court "Commissioners".

In sum, the MJ position is lower than that of the lowest state court judge, and is not in any way a federal judge except by coincidence of naming, with very few powers. The position does not in and of itself inherently convey notability. However, some particular magistrate judges (e.g., Alan Kay, apparently, based on the discussion here) may be notable; their MJ position may be a factor in determining their notability, but it is much more what they've done in the position that potentially makes them notable. TJRC (talk) 03:40, 22 August 2009 (UTC)[reply]

Keep and renominate independently I do not think it can be reasonably maintained that US Magistrate judges are automatically notable the way US District Court judges are. But sometimes they are, and a group nomination of them all has the usual problems of unequal notability. Such a nomination shows, at best, carelessness, in not examining adequately the different articles DGG ( talk ) 23:19, 23 August 2009 (UTC)[reply]
Relist Separately. I agree with DGG. Each Magistrate Judge's notability should be assessed on his or her individual merits. TJRC (talk) 01:00, 24 August 2009 (UTC)[reply]
Relist Separately as per DGG. Edward321 (talk) 23:35, 24 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.