![]() | Heffernan v. City of Paterson is a featured article; it (or a previous version of it) has been identified as one of the best articles produced by the Wikipedia community. Even so, if you can update or improve it, please do so. | ||||||||||||
![]() | This article appeared on Wikipedia's Main Page as Today's featured article on April 26, 2017. | ||||||||||||
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![]() | A
fact from this article appeared on Wikipedia's
Main Page in the "
Did you know?" column on
May 5, 2016. The text of the entry was: Did you know ... that the
U.S. Supreme Court recently
held in
Heffernan v. City of Paterson that a public employer violates the
First Amendment even when it mistakenly disciplines an employee for political activity? | ||||||||||||
Current status: Featured article |
![]() | This article follows the Wikipedia:Manual of Style/Legal. It uses the Bluebook legal referencing style. This citation style uses standardized abbreviations, such as "N.Y. Times" for The New York Times. Please review those standards before making style or formatting changes. Information on this referencing style may be obtained at: Cornell's Basic Legal Citation site. |
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@ Neutrality and Daniel Case: You both seem to have put a lot of work into this article too, so I'm looking for your input. We have a day or two more to submit a WP:DYK nomination, and if either of you have any ideas for a hook, I'd love to hear them. I could do the cliche "Supreme Court ruled in Heffernan that..." but if you think there are more interesting facts of the case, let me know. I will probably nominate this for Good Article status in the coming days as well. Finally, I think that, with both of your additions, this article is well on its way to FA status. We should look into what improvements should be made before then and work to get the article in line with all the various MOS pages. You both really have done a great job, and I hope we can all get our work recognized. Wugapodes ( talk) 17:21, 2 May 2016 (UTC)
"Heffernan sued the city, Rivera, and his superior officers ..." Who is Rivera? This is the only time that name comes up in this article. Concrete Cloverleaf ( talk) 02:37, 5 May 2016 (UTC)
GA toolbox |
---|
Reviewing |
Reviewer: Notecardforfree ( talk · contribs) 20:06, 7 May 2016 (UTC)
I will be completing this review over the course of this weekend, but I want to begin with a few preliminary comments:
Look for a complete review later this weekend. Thanks so much for your efforts to improve this article! Best, -- Notecardforfree ( talk) 20:06, 7 May 2016 (UTC)
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. | For the most part, the article is clear, precise, and well-written. |
![]() |
1b. it complies with the Manual of Style guidelines for lead sections, layout, words to watch, fiction, and list incorporation. | This article complies with relevant portions of WP:MOS. However, see my comments below for a suggestion about the ellipse in the block quotation that appears in the "Opinion of the Court" section. |
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. | |
![]() |
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). | The author utilizes reliable sources. No issues here. |
![]() |
2c. it contains no original research. | No concerns about original research. |
3. Broad in its coverage: | ||
![]() |
3a. it addresses the main aspects of the topic. | Excellent work expanding this article. I think this article's coverage of this topic is sufficiently broad for the purposes of the GA Criteria. |
![]() |
3b. it stays focused on the topic without going into unnecessary detail (see summary style). | This article does not lose focus. |
![]() |
4. Neutral: it represents viewpoints fairly and without editorial bias, giving due weight to each. | I don't think there are any problems with neutrality. However, as discussed in further detail below, you should add commentary that is critical of the Court's opinion if you can find any. |
![]() |
5. Stable: it does not change significantly from day to day because of an ongoing edit war or content dispute. | There have been no conflicts with respect to this article's content. |
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. | This article makes good use of images and there are no issues with copyright, etc. |
![]() |
6b. media are relevant to the topic, and have suitable captions. | The images and their captions are appropriate. |
![]() |
7. Overall assessment. |
My apologies for not returning to this review sooner. My in-laws came to visit for Mother's Day and I've been swamped with work this week. In any event, I think this is a very nice article and an excellent addition to the encyclopedia. I think it is very close to being ready for promotion to GA status, but I have highlighted a few issues that should be resolved first:
"The court reversed an earlier holding to the contrary by the Third Circuit Court of Appeals."I assume you are talking about Ambrose v. Robinson Township. However, I don't think Justice Breyer's opinion ever explicitly stated that Ambrose was no longer good law (in fact, Ambrose is only mentioned once, in a parenthetical citation on page three of Justice Breyer's opinion). I agree that Ambrose likely holds little weight after Heffernan, but because SCOTUS did not explicitly disapprove of the case (and because it may be distinguishable on other grounds), we probably shouldn't say that SCOTUS "reversed" the case.
"picked up a lawn sign for the candidate challenging the city's incumbent mayor in the 2005 election ...."Do you think there is any danger that readers may think that Heffernan was picking the sign up off the ground (rather than collecting it at a distribution center)? If you think there is little chance for confusion, then I would keep it as-is.
"The case took a decade to reach the Supreme Court. For most of that time it was in federal district court, where it was heard by three different judges."At the end of that paragraph, you provide a citation to the Third Circuit's opinion. However, that opinion says nothing about the length of time it took for the case to reach SCOTUS, that it was in district court most of that time, or that the case was heard by three judges. Can you provide citations to substantiate these three pieces of information?
"with instructions to allow Heffernan to present his freedom of association claim and consider the facts from the jury trial"; however, it sounds like the district court was told that it was free to consider evidence (not that it was required to consider that evidence). Can you clarify this point in the article?
"The United States government also filed an amicus brief, meaning the Solicitor General's office would be appearing at oral argument ...."To me, this implies that the Solicitor General was allowed to appear during oral arguments because they filed an amicus brief, but that's not what happened in this case. On December 21, 2015, the Solicitor General filed a motion asking permission to appear at oral argument, and that motion was granted on January 8, 2016. Can you clarify that the Solicitor General appeared at oral argument because the Court granted a motion that permitted them to do so?
"people stuck in traffic who were injured by unconstitutional actions would not be able to sue because none of their rights were violated."Can you clarify the language here? Justice Thomas said that the hypothetical law could cause collateral damage (e.g. in the form of traffic delays), but such harms caused by traffic delays would not be a direct result of that law. Can you make sure this distinction is clear in the article?
"Edelman forwarded interpretations of Heffernan's actions ...."Can you use a different word than "forwarded?" The meaning of this sentence is a little unclear to me.
"the decision was largely praised."This may be true, but it would be great to include commentary that is critical of the opinion for the sake of balance. Of course, if only a minority of commentators have expressed criticism, it should be given its due WP:WEIGHT.
I want to preface these comments by noting that the
Good Article Criteria say that "[i]n-line citations should preferably be of a consistent style."
(See criterion 2(b); emphasis is my own). That said, minor deviations in style will not be fatal to this GA review, but I think you should certainly try, to the extent that it is possible, to follow a consistent style. If you want to use Bluebook, then you should make sure that citations conform to relevant Bluebook conventions. The following comments discuss conventions for Bluebook style citations, but I am happy to answer any questions you may have about Bluebook citations:
Please let me know if any of these comments are unclear or if you have any questions. Thanks again for your incredible work with this article! Best, -- Notecardforfree ( talk) 00:02, 12 May 2016 (UTC)
Earlier this week, I was asked to provide additional comments about this article. In general, I think the article is very well written and in good shape, but I have offered some suggestions for how the article can be improved in anticipation of a potential FA nomination:
"the Court held that a public employee's constitutional rights are violated when an employer disciplines them ...."I would consider changing this to say that their rights "can be violated," or perhaps re-phrase this part of the lead to more narrowly state that this was the holding in this case, because the Court's opinion notes that this is not a categorical rule (see, e.g., slip. op. at 3).
"Justice Stephen Breyer wrote for the majority that the department's belief was all that mattered ...."I would begin this paragraph with a sentence that summarizes the ultimate result of the case (i.e. In an majority opinion written by Justice Breyer, the United States Supreme Court held that Heffernan was deprived of a constitutional right, even though the City acted upon a mistaken belief).
"... the actions were still that of a government official which were supported by unconstitutional reasoning."Can you find a different phrase than "unconstitutional reasoning?" Perhaps you can say something like "the City's actions still constituted an unconstitutional intrusion upon fundamental rights protected by the First Amendment?"
"... "the harm is still the same regardless of the factual basis of the employer's reasoning."The phrase "the harm is still the same" seems a bit vague; perhaps you can say something like "even if a public employer acts upon mistaken beliefs, those actions still prevent the employee from engaging in activities that are protected under the First Amendment." You can probably achieve the same result by consolidating this sentence with the very next sentence in the same paragraph.
"Because of this, the dissent argues that Heffernan cannot succeed as Section 1983 provides a cause of action only for those whose rights have been violated, and Heffernan's rights were not violated."I would divide this into two separate sentences. First, say that Justice Thomas explained that relief under Section 1983 is only available when the government deprives citizens of constitutional rights. Second, say that Justice Thomas argued there was no deprivation of a constitutional right (and explain why there was no deprivation).
Please let me know if any of the above comments are unclear or if you have any additional questions. Thanks again for your fantastic work to improve this article! Best, -- Notecardforfree ( talk) 00:56, 28 May 2016 (UTC)
Wikipedia:Today's featured article/requests/Heffernan v. City of Paterson -- Gerda Arendt ( talk) 18:53, 21 December 2016 (UTC)
Firstly, thank you for this article which I read with great interest. I think it explains rather well what is inherently a complicated legal situation. However, I found difficulty looking up the primary sources and I guess that this is a problem with the general style guidelines for legal articles. I have therefore raised the matter at Wikipedia talk:Manual of Style/Legal#Linking of short ussc references Thincat ( talk) 12:54, 26 April 2017 (UTC)
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![]() | Heffernan v. City of Paterson is a featured article; it (or a previous version of it) has been identified as one of the best articles produced by the Wikipedia community. Even so, if you can update or improve it, please do so. | ||||||||||||
![]() | This article appeared on Wikipedia's Main Page as Today's featured article on April 26, 2017. | ||||||||||||
| |||||||||||||
![]() | A
fact from this article appeared on Wikipedia's
Main Page in the "
Did you know?" column on
May 5, 2016. The text of the entry was: Did you know ... that the
U.S. Supreme Court recently
held in
Heffernan v. City of Paterson that a public employer violates the
First Amendment even when it mistakenly disciplines an employee for political activity? | ||||||||||||
Current status: Featured article |
![]() | This article follows the Wikipedia:Manual of Style/Legal. It uses the Bluebook legal referencing style. This citation style uses standardized abbreviations, such as "N.Y. Times" for The New York Times. Please review those standards before making style or formatting changes. Information on this referencing style may be obtained at: Cornell's Basic Legal Citation site. |
![]() | This article is rated FA-class on Wikipedia's
content assessment scale. It is of interest to the following WikiProjects: | |||||||||||||||||||||||||||||||||||||||||||||||
|
@ Neutrality and Daniel Case: You both seem to have put a lot of work into this article too, so I'm looking for your input. We have a day or two more to submit a WP:DYK nomination, and if either of you have any ideas for a hook, I'd love to hear them. I could do the cliche "Supreme Court ruled in Heffernan that..." but if you think there are more interesting facts of the case, let me know. I will probably nominate this for Good Article status in the coming days as well. Finally, I think that, with both of your additions, this article is well on its way to FA status. We should look into what improvements should be made before then and work to get the article in line with all the various MOS pages. You both really have done a great job, and I hope we can all get our work recognized. Wugapodes ( talk) 17:21, 2 May 2016 (UTC)
"Heffernan sued the city, Rivera, and his superior officers ..." Who is Rivera? This is the only time that name comes up in this article. Concrete Cloverleaf ( talk) 02:37, 5 May 2016 (UTC)
GA toolbox |
---|
Reviewing |
Reviewer: Notecardforfree ( talk · contribs) 20:06, 7 May 2016 (UTC)
I will be completing this review over the course of this weekend, but I want to begin with a few preliminary comments:
Look for a complete review later this weekend. Thanks so much for your efforts to improve this article! Best, -- Notecardforfree ( talk) 20:06, 7 May 2016 (UTC)
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. | For the most part, the article is clear, precise, and well-written. |
![]() |
1b. it complies with the Manual of Style guidelines for lead sections, layout, words to watch, fiction, and list incorporation. | This article complies with relevant portions of WP:MOS. However, see my comments below for a suggestion about the ellipse in the block quotation that appears in the "Opinion of the Court" section. |
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. | |
![]() |
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). | The author utilizes reliable sources. No issues here. |
![]() |
2c. it contains no original research. | No concerns about original research. |
3. Broad in its coverage: | ||
![]() |
3a. it addresses the main aspects of the topic. | Excellent work expanding this article. I think this article's coverage of this topic is sufficiently broad for the purposes of the GA Criteria. |
![]() |
3b. it stays focused on the topic without going into unnecessary detail (see summary style). | This article does not lose focus. |
![]() |
4. Neutral: it represents viewpoints fairly and without editorial bias, giving due weight to each. | I don't think there are any problems with neutrality. However, as discussed in further detail below, you should add commentary that is critical of the Court's opinion if you can find any. |
![]() |
5. Stable: it does not change significantly from day to day because of an ongoing edit war or content dispute. | There have been no conflicts with respect to this article's content. |
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. | This article makes good use of images and there are no issues with copyright, etc. |
![]() |
6b. media are relevant to the topic, and have suitable captions. | The images and their captions are appropriate. |
![]() |
7. Overall assessment. |
My apologies for not returning to this review sooner. My in-laws came to visit for Mother's Day and I've been swamped with work this week. In any event, I think this is a very nice article and an excellent addition to the encyclopedia. I think it is very close to being ready for promotion to GA status, but I have highlighted a few issues that should be resolved first:
"The court reversed an earlier holding to the contrary by the Third Circuit Court of Appeals."I assume you are talking about Ambrose v. Robinson Township. However, I don't think Justice Breyer's opinion ever explicitly stated that Ambrose was no longer good law (in fact, Ambrose is only mentioned once, in a parenthetical citation on page three of Justice Breyer's opinion). I agree that Ambrose likely holds little weight after Heffernan, but because SCOTUS did not explicitly disapprove of the case (and because it may be distinguishable on other grounds), we probably shouldn't say that SCOTUS "reversed" the case.
"picked up a lawn sign for the candidate challenging the city's incumbent mayor in the 2005 election ...."Do you think there is any danger that readers may think that Heffernan was picking the sign up off the ground (rather than collecting it at a distribution center)? If you think there is little chance for confusion, then I would keep it as-is.
"The case took a decade to reach the Supreme Court. For most of that time it was in federal district court, where it was heard by three different judges."At the end of that paragraph, you provide a citation to the Third Circuit's opinion. However, that opinion says nothing about the length of time it took for the case to reach SCOTUS, that it was in district court most of that time, or that the case was heard by three judges. Can you provide citations to substantiate these three pieces of information?
"with instructions to allow Heffernan to present his freedom of association claim and consider the facts from the jury trial"; however, it sounds like the district court was told that it was free to consider evidence (not that it was required to consider that evidence). Can you clarify this point in the article?
"The United States government also filed an amicus brief, meaning the Solicitor General's office would be appearing at oral argument ...."To me, this implies that the Solicitor General was allowed to appear during oral arguments because they filed an amicus brief, but that's not what happened in this case. On December 21, 2015, the Solicitor General filed a motion asking permission to appear at oral argument, and that motion was granted on January 8, 2016. Can you clarify that the Solicitor General appeared at oral argument because the Court granted a motion that permitted them to do so?
"people stuck in traffic who were injured by unconstitutional actions would not be able to sue because none of their rights were violated."Can you clarify the language here? Justice Thomas said that the hypothetical law could cause collateral damage (e.g. in the form of traffic delays), but such harms caused by traffic delays would not be a direct result of that law. Can you make sure this distinction is clear in the article?
"Edelman forwarded interpretations of Heffernan's actions ...."Can you use a different word than "forwarded?" The meaning of this sentence is a little unclear to me.
"the decision was largely praised."This may be true, but it would be great to include commentary that is critical of the opinion for the sake of balance. Of course, if only a minority of commentators have expressed criticism, it should be given its due WP:WEIGHT.
I want to preface these comments by noting that the
Good Article Criteria say that "[i]n-line citations should preferably be of a consistent style."
(See criterion 2(b); emphasis is my own). That said, minor deviations in style will not be fatal to this GA review, but I think you should certainly try, to the extent that it is possible, to follow a consistent style. If you want to use Bluebook, then you should make sure that citations conform to relevant Bluebook conventions. The following comments discuss conventions for Bluebook style citations, but I am happy to answer any questions you may have about Bluebook citations:
Please let me know if any of these comments are unclear or if you have any questions. Thanks again for your incredible work with this article! Best, -- Notecardforfree ( talk) 00:02, 12 May 2016 (UTC)
Earlier this week, I was asked to provide additional comments about this article. In general, I think the article is very well written and in good shape, but I have offered some suggestions for how the article can be improved in anticipation of a potential FA nomination:
"the Court held that a public employee's constitutional rights are violated when an employer disciplines them ...."I would consider changing this to say that their rights "can be violated," or perhaps re-phrase this part of the lead to more narrowly state that this was the holding in this case, because the Court's opinion notes that this is not a categorical rule (see, e.g., slip. op. at 3).
"Justice Stephen Breyer wrote for the majority that the department's belief was all that mattered ...."I would begin this paragraph with a sentence that summarizes the ultimate result of the case (i.e. In an majority opinion written by Justice Breyer, the United States Supreme Court held that Heffernan was deprived of a constitutional right, even though the City acted upon a mistaken belief).
"... the actions were still that of a government official which were supported by unconstitutional reasoning."Can you find a different phrase than "unconstitutional reasoning?" Perhaps you can say something like "the City's actions still constituted an unconstitutional intrusion upon fundamental rights protected by the First Amendment?"
"... "the harm is still the same regardless of the factual basis of the employer's reasoning."The phrase "the harm is still the same" seems a bit vague; perhaps you can say something like "even if a public employer acts upon mistaken beliefs, those actions still prevent the employee from engaging in activities that are protected under the First Amendment." You can probably achieve the same result by consolidating this sentence with the very next sentence in the same paragraph.
"Because of this, the dissent argues that Heffernan cannot succeed as Section 1983 provides a cause of action only for those whose rights have been violated, and Heffernan's rights were not violated."I would divide this into two separate sentences. First, say that Justice Thomas explained that relief under Section 1983 is only available when the government deprives citizens of constitutional rights. Second, say that Justice Thomas argued there was no deprivation of a constitutional right (and explain why there was no deprivation).
Please let me know if any of the above comments are unclear or if you have any additional questions. Thanks again for your fantastic work to improve this article! Best, -- Notecardforfree ( talk) 00:56, 28 May 2016 (UTC)
Wikipedia:Today's featured article/requests/Heffernan v. City of Paterson -- Gerda Arendt ( talk) 18:53, 21 December 2016 (UTC)
Firstly, thank you for this article which I read with great interest. I think it explains rather well what is inherently a complicated legal situation. However, I found difficulty looking up the primary sources and I guess that this is a problem with the general style guidelines for legal articles. I have therefore raised the matter at Wikipedia talk:Manual of Style/Legal#Linking of short ussc references Thincat ( talk) 12:54, 26 April 2017 (UTC)
Hello fellow Wikipedians,
I have just modified one external link on Heffernan v. City of Paterson. Please take a moment to review my edit. If you have any questions, or need the bot to ignore the links, or the page altogether, please visit this simple FaQ for additional information. I made the following changes:
When you have finished reviewing my changes, you may follow the instructions on the template below to fix any issues with the URLs.
This message was posted before February 2018.
After February 2018, "External links modified" talk page sections are no longer generated or monitored by InternetArchiveBot. No special action is required regarding these talk page notices, other than
regular verification using the archive tool instructions below. Editors
have permission to delete these "External links modified" talk page sections if they want to de-clutter talk pages, but see the
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source check}}
(last update: 5 June 2024).
Cheers.— InternetArchiveBot ( Report bug) 08:07, 7 October 2017 (UTC)