L33th4x0rguy

Sherman Act

Hi there, l33th4x0rguy, I noticed your recent edit to the article on the Sherman Antitrust Act. Your edit is fine and I have not modified it. However, I wanted you to be aware that your edit summary is inaccurate. As you stated, there was competition law in the U.S. before the Sherman act. That law was common-law based. State law and Federal law are different. Federal courts, officially speaking, do not have lawmaking power. Therefore, the common law was not U.S. Federal law. It was state law. The article correctly stated that the Sherman act was the first U.S. government act to regulate competition. Just thought you might like to know. Non Curat Lex (talk) 21:18, 28 April 2008 (UTC)

Thanks for the response, however it is not entirely accurate.

While Erie did in many ways relegate federal common law to obsolescence, there remain a number of areas where federal courts do, officially, have positive law making power. Areas of exclusive federal jurisdiction in particular; the district of columbia, indian tribes, and admiralty law come to mind immediately. More to the point though, in 1890 the issue of federal common law was governed by Swift which did endorse federal common law. At the time of the passage of the Sherman Act, and given the history of the act at its passage, there was federal common law that placed restrictions on restraint of trade in contract and otherwise. This is in part evidenced by some of the floor debates about amendments to the original act. Senator Hoar and Morgan both pointed out the additional advantages to codifying the common law, including the federal common law: extending it to foreign commerce, as well as giving private rights of action and the statutory damages.

Even today, saying there is absolutely no federal common law is incorrect. The same day that Erie was released, Brandeis authored Hinderlider v. La Plata River Co., 304 U.S. 92, 110. That case, involving an interstate water body explicitly used federal common law. For more on the remaining areas of federal common law take a look at Banco Nacional De Cuba v. Sabbatino, 376 U.S. 398, 426 (1964). Also see Tex. Indus. v. Radcliff Materials, 451 U.S. 630.

Also, it would be inaccurate to say that the Sherman Act was the first federal act to regulate competition. The Interstate Commerce Act of 1877 certainly regulated competition amongst the railroads, setting rates, freights, and schedules. However, as the article's written now, it says the Act was the first to regulate cartels and trusts, as well as the first anti-trust statute. I believe that phrasing is correct.LH (talk) 05:58, 1 May 2008 (UTC)

Hi LH. Your reply is interesting.I hope you'll indulge me in a few follow-up responses.

First, it would be a mistake to say my comment as based on Erie. To conceive the issue as an Erie problem is to put the cart before the horse. I am mindful of the distinction between federal common law and "Federal General Common Law." In fact, I created the wiki article on Hinderlider where there was none before (it's still just a stub though, b/c I've been too busy to work on it.) But While there is and has always been Federal Common Law, even when there was "Federal General Common Law" not all Common Law was Federal Law.

I'll elaborate. Federal Courts were, at the time, "common law courts," and capable of being general lawgivers, like state courts or the courts of England. This was the case from the inception of the Federal Judiciary in 1789 until April 25th 1938, Federal Courts freely followed Common Law adjudication. Moreover, in Swift, Justice Story didn't create that power; he merely clarified the status quo. Before the early 19th century, Common Law Judges in the U.S. and in England did not pay attention to "choice of law," especially in common law cases. Story, the most astute of any then-living American attorney when it came to conflicts of law, having studied European approaches, opted to treat common law as transcendant, rather than as a positive state act. Common law wasn't, according to the Swift expalanation, the act of any state, but something with a life its own. Today, and for nearly 80 years, it has been widely held that this is a philosophically vacuous view of law, be it common law or statutory law.

But while Federal Courts were common law adjudicators at the relevant times, that doesn't mean that all common law was Federal law. As weak as the then-existing philosophies of law were, the Federal government's understanding of law did distinguish, even in the 18th and 19th centuries, a separation of lawmaking power. The Federal Government is a government of "enumerated powers," not "general power." That was important to the Framers as a way of preventing an American dictatorship, or an American oligarchy.

It was a 20th century idea, based on emerging philosophies of law and politics, that Federal Courts should not be true common law courts, because it gave them undue legislative power. But long before the doctrinal revolution in Erie, even back in the days of the flawed view of law, and choice of law, embodied by Story and the Swift court (and its predecessors and its successors), our lawmakers and judges acknowledge a difference between cases in federal court, and federal question cases. That distinction is in Art. III of the Constitution itself.

Federal courts are courts of limited in subject matter jurisdiction (much like the government of which they are a branch was created to be a government of limited jurisdiction). Art. III, s. 2 distinguishes between cases "arising under" the laws of the U.S. government, and those "between citizens of different states." The distinction indicates that the framers envisioned Federal Courts as hearing cases that presented "federal questions," but also cases that did not ("diversity cases"). But at the time, there was no view of common law as the positive law of any sovereign; the consensus was that common law was Platonic, with an existence transcending state or national boundaries. Impliedly, the Framers did not incorporate all common law into being federal law just because they permitted Federal Courts to [potentially] hear and decide common law cases.

To take the view that because there was Federal General Common Law, the common law of restraint of trade was Federal law is flawed for several reasons. First, it's anacrhonistic. At the time that the courts were engineered to followed common law, the archtects of those courts simply did not have in their contemplation, a philosophy of law that viewed common law adjudication itself as a legislative state act. That philosophy did not emerge until the early 20th century in the writings of Holmes and the "legal realist" school. Additionally, to apply the modern view "backwards" would have the interesting but undesirable effect of making the "arising under" clause and the "diversity" clause of s. 2 redundant. In fact, today, if we had not abolished the Fed. General Common Law in Erie the clauses would be redundant. But since we do not presume that legislators had the intent not to make redundant utterances, I take this as evidence that the framers meant not to take the view of common law adjudication in federal court as acts of federal law.

It should not matter either that there is an overlap between the particular common law doctrine and an enumerated power of Congress. You might argue that because restraint of trade overlapped with the Art. I, s. 8, cl. 3 "interstate commerce" power of Congress, that common law decisions of Federal courts that also involve interstate commerce, as arguably any federal case applying the decisional rule of the restraint of trade doctrine would probably be, is special, and may enjoy the status of non-general federal common law, such as constitutional common law or interstitial common law. But I can tell you with great certainty that it doesn't. There is a limited crossover that the court has sometimes held that Congress can authorize the court to make common law, in an area where Congress has an Art. I, s. 8 power to act. For example, in Lincoln Mills (although the idea absolutely outraged Justice Frankfurter, who wrote a very articulate and famous dissent in that case!).

There's also a "total preemption" exception to the "well-pleaded complaint rule" of 28 U.S.C. 1331. Normally a case does not 'arise under' federal law for s. 1331 unless it creates the plaintiff's cause of action; a case where federal law creates only a defense, such as preempting the plaintiff's state law cause of action, is not deemed a federal question. (Mottley.) However, there is an exception when a "field" is "totally preempted" by Federal law, in which the state law based suit is preempted by Congress. Nevertheless, that does not apply here, because the commerce power has always been held to be non-exclusive, and concurrent.

In other words, there is nothing about the restraint of trade doctrine's relationship to interstate commerce that makes it different from other common law rules. The lead cases on the doctrine weren't even American, but English, preexisting the U.S. There are not, to my knowledge, many cases in the federal reporters about them. Even to the extent that there are some, the courts hearing these cases would not have viewed their role as deciding federal law (although not state law either), but something different entirely. Even they would have realized it was inconsistent with the Constitution to treat it as Federal law.

When I refer to it today as an exercise in following "state law" it is an anacrhonistic exoression. I am applying today's thinking to explain thinking in a way it wasn't thought of at the time it was thought. However, I am not applying Erie doctrine retroactively or ignoring the Swift doctrine either. I'm stating, charitably, what was "actually happening." It certainly wasn't Federal law the courts were applying, even if they didn't realize that they were supposed to look at it as state law.

Second, you make an interesting point about the existence of other trade regulations. As I see it, there is a sense in which the Sherman act has "firstness," and a sense in which it doesn't. It was not, by any means, the first act to regulate competition in a particular trade. Your example of the railroad act shows that. (But then, why would you write that it was the first statute, if you are going to disagree with that also??) The railroad acts were not the first act of congress to regulate a particular trade either. Any regulation of a particular trade will affect competition in the market or markets relevant to that trade. However, the Sherman act was (as far as I know) the first act, other than the common law doctrines, to regulate competition for any market' and across all markets within the jurisdictional reach of the U.S., that was not a regulation of a particular industry.

I hope this explains a little bit better what I meant. Non Curat Lex (talk) 22:40, 1 May 2008 (UTC)

Thanks for the reply. Interesting discussion. I suspect we're really not in disagreement on the vast majority of points (if any) so I'll try to answer to tease out any lingering questions.

To take the view that because there was Federal General Common Law, the common law of restraint of trade was Federal law is flawed for several reasons. First, it's anacrhonistic.

I agree. My point is not that the Sherman Act was only a codification of federal common law, or that federal common law even comprised the bulk of what congress intended to federalize when enacting an anti-trust statute. I only take issue with the notion that federal law (including judge made common law) was silent on issues of restraint of trade prior to the Sherman Act (I say this with understanding of the distinction between a federal court sitting in diversity too).

At the time that the courts were engineered to followed common law, the archtects of those courts simply did not have in their contemplation, a philosophy of law that viewed common law adjudication itself as a legislative state act.

That may be true in terms of how a 19th century court thought of the common law. In fact Swift certainly gives credibility to this approach. But the nomenclature used today shouldn't be similarly naive. Obviously common law precedent was not legislative, but even in the 19th century, adjudications of courts were still considered "law." Whether they thought they were creating it or "revealing it", is relevant in determining whether they cared about choice of law, but not in whether or not they considered it a "law." I'm not in any sense arguing that Swift was correct, only that it was in effect.

Whether these decisions under Swift were state or federal law is, I suppose, the relevant question. I understand your point to be that because no court ever thought they were making the common law as they declared it, then none of that common law was federal law. I define federal law broader--namely as law created by federal entities. That would encompass statutes, federal common law, etc. I understand your point to be that all of the common law that existed though was state law based. I disagree with that conclusion because if the judges are never creating the law then the law is not state law for the same reason it is not federal law.

I also realize that your point might instead be that even if federal court judges were applying federal common law which was law they created themselves, they believed that they were applying state law (as directed by the rules of decision act) even when using the federal common law. I might actually find that argument persuasive. But there are instances where there was no state law to apply. Such as areas of exclusive federal jurisdiction (again, admiralty, indian nations, the district, and other limited international style areas) where the feds have exclusive federal rules that determine outcomes. Those rules are laws, and are thus federal laws. I'm reasonably convinced too that the law applied in those instances embodied, if they were not themselves the embodiment for, the principles of the Sherman Act.

There were exclusively federal restraint of trade cases that predated the Sherman Act. (See, e.g., Thompson v. The Catharina, 1795 U.S. Dist. LEXIS 3 (D. Pa. 1795) (maritime restraint of trade, note 9; sources of maritime law generally); Or. Steam Navigation Co. v. Winsor, 87 U.S. 64, 67 (U.S. 1874))

(See also, Wallingsford v. Allen, 35 U.S. 583, 594 (U.S. 1836) (noting that Maryland law is purely persuasive and not binding; distinguishing the application of common law coverture)); Fallon v. Chronicle Publishing Co., 1 MacArth. 485 (D.C. 1874) (demurring contract in restraint of trade; D.C. case); Odlin v. Insurance Co. of Pennsylvania, 18 F. Cas. 583 (C.C.D. Pa. 1808) (maritime)). It would be incomprehensible to say that cases decided by federal courts, under exclusively federal jurisdiction, are not decisions under federal law.

You might argue that because restraint of trade overlapped with the Art. I, s. 8, cl. 3 "interstate commerce" power of Congress, that common law decisions of Federal courts that also involve interstate commerce, as arguably any federal case applying the decisional rule of the restraint of trade doctrine would probably be, is special, and may enjoy the status of non-general federal common law, such as constitutional common law or interstitial common law. But I can tell you with great certainty that it doesn't.

My point was not to argue that any interstate case would be governed by Federal Common law, or should today. I would think Erie put an end to that. However, in some instances there are. For instance, disputes on Lake Michigan, or Lake Tahoe--interstate waterways--might well be admiralty cases and thus, governed by federal maritime law under reverse erie doctrine. You also bring up a good point I am curious about. If you acknowledge other areas of judicial decision making, such as constitutional common law, would you consider those federal laws? I would, and perhaps that is the primary question here.

But then, why would you write that it was the first statute, if you are going to disagree with that also??)

I don't disagree with that. The sentence that is in the article reads: "[The Sherman Act] was the first United States government statute to limit cartels and monopolies. It is the first and oldest of all U.S., federal, antitrust laws." I do not believe the ICA regulated cartels and monopolies nor do I believe that the ICA was an antitrust law. However, I do not believe the statement "the Sherman act was the first U.S. government act to regulate competition" is accurate. I wasn't very clear what I was responding to there; my apologies.LH (talk) 00:51, 2 May 2008 (UTC)

You're right - we do not have any substantial disagreement. Thank you for (a) clarifying, (b) indulging me in a little academic musing and (c) helping improve the article in a way that to others may look small, but actually contains (as we've just explored) a world of issues!

I have just two things I'd like to add (again, not in substantial disagreement, but further refinement of the issues).

I wouldn't say that federal judges deciding common law cases pursuant to Swift-style federal general common law ("FGCL") thought they were applying state law. You have a pretty good example that they didn't. I don't disagree. (I say "kind-of" because inter alia we're taking language from a maritime case, and maritime cases are a variant of "arising under" cases where jurisdiction is, as you say, exclusive, as opposed to "diversity cases" where it is most definitely concurrent. Federal courts still have exclusive maritime jurisdiction and create "specialized federal common law" for it, unaffected by Erie to this day. I also have to say "Swift-style," because I maintain the "Swift doctrine" preceded the Swift decision by about 50 years.)

Nor would I say they weren't acting on the part of the government and de facto "making law" because the common law process involves applying law made by other judges, or judges making new law to solve the case in the guise of applying law made by other judges. Hence, I don't just say that judges in private disputes are still acting governmentally, I often say "judges do legislate." I don't think you can live in a post-Holmes, post-Cardozo world and think otherwise!

I'll tell you what I think is important though: whether it's maritime law or pre-Erie F.G.C.L., the Judges doing it, did not until post-Holmes, think they were positing any law. They did not intend to be legislators. They did not intend to insert a government interest into private disputes they resolved. The second misconception of the role of the court is not too important; whether a court intends to be a state actor or not, because it brings the coercive power of the state to settle a dispute, it is. It just is.

The second misconception is a little trickier. Legislation is intentional business (although it may have unintended consequences), but in formal terms, there's a difference between a proposed law, and an enacted law. It's well settled that a case has no more preclusive effect that the court intends, or is authorized, to give it. For example, under state law, when a state court hears a motion to dismiss (on a demurrer or the equivalent motion to Fed. R. Civ Pro. 12(b)(6), it has the power to decide that the case is involuntarily dismissed without prejudice, which means the plaintiff may refile, or it can, if the appropriate and extraordinary circumstances for such a sanction are met, turn it into a judgment on the merits, and make its dismissal preclusive.

By the same token, I would argue, the legislative effect of case law can differ - it has the force of law only between the parties, but it can have a great deal of precedential impact in future transactions or cases, or it can have none. There are several factors that determine that, one of them being the predilictions of judges in future cases, and how well future judges think past judges did in articulating the rules, and whether the identical case is ever litigated again. Another factor, however, is the intent of the court issuing the decision. If a court phrases its decision as being in terms of one body of law that subsequent cases aren't going to rely upon, they're making it substantially less likely that subsequent courts would give it weight. Federal courts in diversity cases during the Swift years, by intentionally populating "common law" decisions, were creating decisions that were very limited in where they would apply; though they had many of the legislative features of common law adjudication, they couldn't really be cited in state court, and weren't really meant to alter any federal standard of care. If they were, they would be making federal law for the general welfare, which is not a power the federal government has. So, they weren't trying to "bind the nation." At most, they had a quasi-legislative hope that, if they interpreted the common law better than the next court, someone else would cite them approvingly - but that would still be a positive act of whatever court next cited them.

Put another way, there's two ways in which a court "makes the law." In one of these ways ,federal courts in diversity cases were really making federal law, because they were acting on behalf of the state, validly committing the coercive power of the state to a certain decision that they had the power to make. But in another way, they weren't, because they did not view themselves as having the power to create "law" to govern any other transaction, past or future.

Also, while you'd still acknowledge a maritime case in U.S. court as ultimately applying U.S. law as they act on behalf of the U.S. Government, judges hearing Maritime cases aren't strictly applying "U.S. federal law" for rules of decision, nor creating new federal law to bind all U.S. citizens or courts.

My only point is that I still have some hesitation about saying that common law decisions of Federal courts pre-Erie were "making federal law," because it would exceed the intent of the judges who decided them. I agree that the Sherman Act wasn't the first U.S. government act to regulate competition. The Sherman act has the firstness of being the first affirmative act intended to deal with anticompetitive practices, as opposed to a judicial act that has quasi-intentionally legislative effects, not intended to be lawmaking or even entirely governmental, as understood at the time. Your apology is absolutely unnecessary. Thanks again. I hope you'll join the party at WP:LAW if you haven't already. Non Curat Lex (talk) 23:19, 2 May 2008 (UTC)

Thank you

... for making me think, once again. Non Curat Lex (talk) 01:52, 5 September 2008 (UTC)

Hahah, it took me a while to figure out what exactly you were referring to. I appreciate the compliment and I return the same to you. I look forward to more in the future. (copied to your talk page as well) LH (talk) 22:36, 9 September 2008 (UTC)

Commercial links?

Methinks you acted hastily in removing 2 external links which helped to shed more light on the subject of ch.13 bankruptcy. Do you know what "cram down" means? The term is used a lot these days, and it is not covered anywhere in WP. The link covered it. Where was the commerciality? Nothing was offered for sale on these sites, but only served as enlightening sources. Please maintain your NPOV and reverse your removals. Or do an article defining cram down. That would be helpful. —Preceding unsigned comment added by 76.172.56.255 (talk) 20:06, 13 November 2008 (UTC)

Removing commercial links is standard procedure, particularly for the Bankruptcy pages which tend to attract a lot of these links. See WP:LINKSPAM for full details. Even non-spam links should be removed if they do not add something extra to an article: WP:LINKSTOAVOID. If you believe those links do not fall within the category, please discuss it on the Talk page. Cramdown in chapter 13 is merely a procedure to overcome secured creditor objections to a plan. Specifically it's § 1325(a)(5)(B). LH (talk) 20:15, 13 November 2008 (UTC)

revert Electronic Yellow Pages

Please see the article Internet. The internet is the communication network, the many linked documents, such as the Electronic Yellow pages, are part of the World Wide Web. Curious why the revert.69.106.243.72 (talk) 03:12, 25 November 2008 (UTC)

Jennifer Kathleen Phillips

Hi. The page your tagged for speedy seems notable. Not pretty sure but would you mind checking possible reliable sources? Thank you. --Efe (talk) 09:23, 1 December 2008 (UTC)

Based on context in the article, the subject seemed non-notable. If the subject's notable the article should indicate why. The article as is suggests some publications but that's the only plausible notability claim. If the article's notable, then it's my mistake; however in any case, there is severe cleanup needed. LH (talk) 09:29, 1 December 2008 (UTC)

Yep, the article needs clean-up, but there are lines there that suggest notability and importance. Could you notify the editor about this? Thank you. --Efe (talk) 09:31, 1 December 2008 (UTC)

This link suggests that the article is notable. --Efe (talk) 09:34, 1 December 2008 (UTC)

Note: Article subsequently deleted

More patience required?

Thanks for tagging 2007 Tour de las Americas less than 10 mins after creation. Alternatively, why not just address the problem rather than leaving it? Regards. bigissue (talk) 14:30, 10 December 2008 (UTC)

I tag articles that need improvements in order to bring attention to the specific problems, and to help categorize them so other users can find them and address the problems. This is one of the many little tasks that's going on all the time on Wikipedia. Tagging is helpful and a necessary part of wikipedia, and it helps create a list of articles that people can contribute towards when they're inclined to do so.

Wikipedia tags are available and widely deployed for exactly this reason. If the consensus of editors that make up Wikipedia had concluded that all issues should be immediately changed, tags would not be necessary. This is not the consensus and the fact that the tags exist demonstrates as much.

I do at times make changes rather than just tag issues, but it's not always efficient for me to make the specific changes. For instance, with 2007 Tour de las Americas, you know a lot about the subject, have been working on the article, and are in the best position to improve it. I would hope you would appreciate specific guidance, particularly early in the article's development.

I'm sorry if you were offended by the tag's inclusion, but I'd chasten you to be more circumspect in your tone when responding in the future. I'm only trying to improve the article on a subject of your interest. LH (talk) 00:14, 11 December 2008 (UTC)

I have no issue with the tag, the word "golf" certainly needed including, just the carefree manner in which it was applied. As you are clearly aware, it is not uncommon for newly created articles to take time to develop into something useful. I just don't happen to think that immediate tagging of articles in this way is helpful. A more civil way to raise concerns about the quality of a new article would be to drop the creator (in this case me) a note to highlight any issues, either as well as or instead of adding the tag? Regards. bigissue (talk) 10:03, 11 December 2008 (UTC)

Our key difference appears to be how we regard the emotional import of tagging a page. I don't believe it's meant to be insulting if done in good faith, and wikipedia guidelines generally indicate as much. As discussed above, tagging is a quick and efficient way of indicating this, and is also non-personal. Notifying a user directly is not only more time consuming (requires more clicks, and also requires checking history to figure out who's most appropriate to send the message to) but suggests the article's problems are the fault of a particular user. I realize now, in this case you were the only contributor, but in many cases articles need addressing because of their sum and not their pieces.

I continue to believe that tagging is an efficient and necessary part of wikipedia, so long as it is in good faith. I appreciate your contributions and also want you to know that my addition of the tag was in no way a personal attack or comment directed towards you. LH (talk) 22:16, 11 December 2008 (UTC)

Red blood cell reference

Hi, thanks for your additions to red blood cell. In the citation template for your reference, you list the pages= and also the page= parameter, but Template:Citation says that only one of the two should be present. Unfortunately I don't know which page you're referring to, so I can't fix it myself. Cheers, AxelBoldt (talk) 17:09, 12 December 2008 (UTC)

Thanks for the heads up. I thought it was asking for the total page count of the book. I'll go through the places where I used it and correct it. Thanks again. LH (talk) 22:45, 12 December 2008 (UTC)

Centre

I'm just curious, is there some particular reason why you object to the spelling as 'centre', instead of 'center'? The project is an international one, not an American one, and the 'centre' spelling happens to be correct in virtually every country where English is spoken as a first language except the US. Just to be clear, this wasn't a spelling error. I'm not really sure that this was a valid edit, and would have reversed it, apart from the fact that the edit also included several fact tags that were appropriate. Just food for thought for you. Emrgmgmtca (talk) 12:26, 17 December 2008 (UTC)

I only changed it because the previous style was to use the U.S. and not commonwealth (Canadian in this case) spelling. The Wikipedia style guide is to use the local spelling when the article is on a local topic, and when that is ambiguous (as in this case, when the Canadian and American spellings differ) then to use whichever style is first established. I see now that there was actually one instance of each spelling in this article, so my change was premature (unless there are other versions of American spelling taking precedence--I didn't check) however the initial style (take a look at a version from July 2007) used was "center". To perfectly adhere to the guidelines the initial inclusion of "centre" should have been changed. That said, I don't have any desire to change it and would leave it to others to change the remaining ones. Here's the link for more info. LH (talk) 20:38, 17 December 2008 (UTC)

Dreyse Model 1907

That wasn't a direct quote, but rather a rewording, hence no quotation marks. -- moe.RON ^{Let's talk | done} 20:15, 23 December 2008 (UTC)

Ok. My apologies. I guess I didn't check them together; it just sounded very similar. LH (talk) 20:17, 23 December 2008 (UTC)

User:Doirocoa

Hello L33. Your advice to this user will probably fall on deaf ears. For a long time now I have to fix and revert most of his edits. He apparently has no regard for format, a major headache-in-good-faith if you will. Oh boy. :-/ Regards, Húsönd 21:15, 23 December 2008 (UTC)

Thanks for the heads up. I almost resorted to writing a script, but hoped saying something would be quicker. I guess not. LH (talk) 21:26, 23 December 2008 (UTC)

Re: Kakatpur Mangala Temple

You found the introduction unclear. What clarifications would help users make it clearer? --Sidsahu (talk) 07:49, 5 January 2009 (UTC)

These items were what I was thinking of

• Country (is it India?)
• Religion associated with the temple (there is a cult listed, but what larger religion is it? Is there one?)
• It's unclear what Maa Mangala is. If it's a diety, that should be indicated; if it's a statute that too; etc.
• Related context, such as whether or not there are many similar temples, how this fits into a larger set of practices, how significant the temple is, other things like this. Of course I know none of this, so I just tag articles that are unclear to me, since if it's unclear to me it may well be unclear to another reader too.

Thanks for your help on the article. LH (talk) 08:27, 5 January 2009 (UTC)

Intellectual property lead

Hey, L33th4x. I dropped some comments about the lead to intellectual property on the talk page. Demian12358 (talk) 06:19, 15 January 2009 (UTC)

Thanks for having another look, h4x. I added some more discussion over there. Demian12358 (talk) 01:23, 16 January 2009 (UTC)

Lilies

Hi LH.

I agree my usage of the name Datura was not accurate, (my excuse is that I've always referred to both genera by the older name, used as a common name - e.g. 'that's a datura of some kind'. On the question of a note to say that some 'lilies' are poisonous, the word Lily redirects to Lilium, and this article is unambiguously about the true lilies which are generally agreed not to be poisonous. So I feel it would be inappropriate there.

However, Lily_(disambiguation) may need a link to this species of Brugmansia. I would not include this unless the additional term 'lily' in the name is very common. Looking at Brugmansia_suaveolens, where the name is only given as 'Angel's tears', it seems that the added 'lily' is not always used.

I note that both Brugmansia and Datura have long had sections stating that they are dangerously poisonous. However neither the Brugmansia_suaveolens article (assuming that it is the species referred to in the original report) nor its sister species have any text stating that they are poisonous.

Going back to true lilies, although many species are eaten by people, I have a vague recollection of some people having adverse reactions to some species. This might just be confusion of names though; e.g. some day lilies are somewhat toxic.

Thanks. Imc (talk) 17:06, 22 January 2009 (UTC)

Merger

You never finished your merger proposal by properly tagging the destination page (African Americans in the United States Congress) and by commenting. I am not sure where you stand.--TonyTheTiger (t/c/bio/WP:CHICAGO/WP:LOTM) 21:03, 25 January 2009 (UTC)

Why did you revert my Ned Flonders post?

Seriously, why. I'm clueless.

Your edits were reverted because they were vandalism. You replaced Ned Flanders with Ned Flounders. Also, I did not revert your edits. Another user did. I placed a message informing you of this on your talk page. LH (talk) 02:40, 26 January 2009 (UTC)

CSD

Hi there. If you're going to regularly patrol new pages, please brush up on the criteria for speedy deletion. Smelly socks did not even come close to the definition of patent nonsense. It's not helpful to delete pages which shouldn't exist on an invalid justification. Bigbluefish (talk) 15:19, 7 February 2009 (UTC)

I am familiar with the criteria and I disagree with your interpretation of it. This article is patent nonsense, but if you are going to assert that because it uses complete sentences (sort of) and actual words it is not, then it qualifies for G2, a test page. It's unclear what the distinction is between G1 and G2 under that interpretation, but even so, this page is also G3 vandalism. If, by some tremendous good faith "Smelly socks" is a reference to a film, or a saying, or socks in a hamper, and that is somehow notable, then please explain how this doesn't then fit under CSD A1 (perhaps even A3).

I do not appreciate this hyper technical approach to CSD categories. I am not tagging plausibly useful articles in an effort to slip them past Afd, but doing routine vandalism patrol. LH (talk) 23:01, 8 February 2009 (UTC)

Template:USBankruptcy

Nice template. This was definitely needed. --Eastlaw ^talk ⁄ _contribs 04:24, 17 March 2009 (UTC)

Thanks, I agree. If it's not obvious, I got the formatting from the Tax guys. Maybe more can be done with the template formatting. LH (talk) 04:27, 17 March 2009 (UTC)

Legal Ethics

I think the link you deleted from my 7/16 edit should be included in this page. As mentioned in the Enforcement section, California and Maine have unique guidelines and processes for enforcement of legal ethics issues. The current link provided in this section goes to the CalBar website - not only is the link broken, but the way it is presented suggests that Maine's guidelines may be similar to California's (I don't know if this is true, but I suspect it is not.) The link I provided in my original edit is the best outline of California's process I have found online and I think it provides valuable additional information regarding the subject of legal ethics. I would suggest that it should be put back the way I had it originally or it should be used to replace the broken CalBar link (with some additional clarification regarding Maine.) I would like to hear your thoughts on this. —Preceding unsigned comment added by XRobinson (talk • contribs) 06:06, 20 July 2009 (UTC)

WP:Hornbook -- a new WP:Law task force for the J.D. curriculum

Hi L33th4x0rguy,

I'm asking Wikipedians who are interested in United States legal articles to take a look at WP:Hornbook, the new "JD curriculum task force".

Our mission is to assimilate into Wikipedia all the insights of an American law school education, by reducing hornbooks to footnotes.

• Each casebook will have a subpage.

• Over the course of a semester, each subpage will shift its focus to track the unfolding curriculum(s) for classes using that casebook around the country.
• It will also feature an extensive, hyperlinked "index" or "outline" to that casebook, pointing to pages, headers, or {{anchors}} in Wikipedia (example).
• Individual law schools can freely adapt our casebook outlines to the idiosyncratic curriculum devised by each individual professor.

• I'm encouraging law students around the country to create local chapters of the club I'm starting at my own law school, "Student WP:Hornbook Editors". Using WP:Hornbook as our headquarters, we're hoping to create a study group so inclusive that nobody will dare not join.

What you can do now:

1. Add WP:Hornbook to your watchlist, {{User Hornbook}} to your userpage, and ~~~~ to Wikipedia:Hornbook/participants.

2. If you're a law student,

• Email http://en.wikipedia.org/wiki/WP:Hornbook to your classmates, and tell them to do the same.
• Contact me directly via talk page or email about coordinating a chapter of "Student WP:Hornbook Editors" at your own school.

(You don't have to start the club, or even be involved in it; just help direct me to someone who might.)

3. Introduce yourself to me. Law editors on Wikipedia are a scarce commodity. Do knock on my talk page if there's an article you'd like help on.

Regards, Andrew Gradman ^talk/_WP:Hornbook 05:25, 31 July 2009 (UTC)

Donnie dumphy

Hi there. I noticed that the Donnie dumphy discussion page has been blanked out and vandalized. I have undone the cleanup and reverted the page to its last edit; please let me know if I have done something wrong! Thank you. McMarcoP (talk) 08:34, 18 August 2009 (UTC)

Proposed deletion of Mack v. United States (Ninth Circuit)

The article Mack v. United States (Ninth Circuit) has been proposed for deletion because of the following concern:

Non-notable intermediate court of appeals opinion. Was only in effect for a year before it was reversed by the Supreme Court in Printz v. United States. All information in this stub is already in the Prinz article.

While all contributions to Wikipedia are appreciated, content or articles may be deleted for any of several reasons.

You may prevent the proposed deletion by removing the {{proposed deletion/dated}} notice, but please explain why in your edit summary or on the article's talk page.

Please consider improving the article to address the issues raised. Removing {{proposed deletion/dated}} will stop the proposed deletion process, but other deletion processes exist. The speedy deletion process can result in deletion without discussion, and articles for deletion allows discussion to reach consensus for deletion. TJRC (talk) 19:22, 12 November 2010 (UTC)

WikiProject Cleanup

Hello, L33th4x0rguy. You are invited to join WikiProject Cleanup, a WikiProject and resource for Wikipedia cleanup listings, information and discussion. To join the project, just add your name to the member list. Northamerica1000(talk) 12:28, 29 February 2012 (UTC)

Just to let you know

You have been mentioned at Wikipedia:Missing Wikipedians Ottawahitech (talk) 14:55, 18 December 2012 (UTC)

PGP-Key

Hello L33th4x0rguy,
the PGP-key you provide on your user-page is expired. Could you please renew it so it can be more usable? :-). --DaB. (talk) 13:53, 18 August 2013 (UTC)

Proposed deletion of Taylor Complex Fire

The article Taylor Complex Fire has been proposed for deletion. The proposed deletion notice added to the article should explain why.

While all constructive contributions to Wikipedia are appreciated, content or articles may be deleted for any of several reasons.

You may prevent the proposed deletion by removing the {{proposed deletion/dated}} notice, but please explain why in your edit summary or on the article's talk page.

Please consider improving the article to address the issues raised. Removing {{proposed deletion/dated}} will stop the proposed deletion process, but other deletion processes exist. In particular, the speedy deletion process can result in deletion without discussion, and articles for deletion allows discussion to reach consensus for deletion. Zackmann08 (talk) 05:15, 18 January 2014 (UTC)

ArbCom elections are now open!

Hi,
You appear to be eligible to vote in the current Arbitration Committee election. The Arbitration Committee is the panel of editors responsible for conducting the Wikipedia arbitration process. It has the authority to enact binding solutions for disputes between editors, primarily related to serious behavioural issues that the community has been unable to resolve. This includes the ability to impose site bans, topic bans, editing restrictions, and other measures needed to maintain our editing environment. The arbitration policy describes the Committee's roles and responsibilities in greater detail. If you wish to participate, you are welcome to review the candidates' statements and submit your choices on the voting page. For the Election committee, MediaWiki message delivery (talk) 12:54, 23 November 2015 (UTC)

Just to let you know

You have been mentioned at Wikipedia:Missing Wikipedians. Ottawahitech (talk) 00:42, 4 January 2016 (UTC)please ping me

your recommendations sought for improvements to Cybercrime article

Two things atm, Tight cases~Documented cases and warfare/terrorism/ extortion. Some contributors have gone way overboard on the article over the last 10 years. Could use a bit of help, perhaps on the article talkpage? 126.243.109.174 (talk) 18:30, 13 April 2018 (UTC)

Oddly, the talkpage was protected for some reason or other. Just a heads up. 126.243.109.174 (talk) 18:31, 13 April 2018 (UTC)

Proposed deletion of Kawle (surname)

The article Kawle (surname) has been proposed for deletion because of the following concern:

No evidence of notability, fails WP:NNAME, no sources. No sources or WP:SIGCOV found to indicate notability.

While all constructive contributions to Wikipedia are appreciated, pages may be deleted for any of several reasons.

You may prevent the proposed deletion by removing the {{proposed deletion/dated}} notice, but please explain why in your edit summary or on the article's talk page.

Please consider improving the page to address the issues raised. Removing {{proposed deletion/dated}} will stop the proposed deletion process, but other deletion processes exist. In particular, the speedy deletion process can result in deletion without discussion, and articles for deletion allows discussion to reach consensus for deletion. AllTheUsernamesAreInUse (talk) 06:43, 20 April 2024 (UTC)