Wikipedia:Articles for deletion/Ahanchian v Xenox Pictures Inc., et al

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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 Delete/draftify. Simultaneously closing Wikipedia:Articles for deletion/Ahanchian v Xenox Pictures Inc., et al and Wikipedia:Articles for deletion/Cyrus Ahanchian. Both discussions have clearly found consensus that this person and this case have not been shown to meet our notability guidelines, and as such, there is consensus to delete. However, I rarely decline good-faith requests for draftspace work, and in this case there is a possibility that one notable article may be rescued where two cannot; hence, I'm draftifying. I am going to WP:IAR a little, and require that, given the clear consensus in the AfDs, a) this article/these articles only be recreated via AfC, b) these discussions be linked in a way that the AfC reviewer will read them, and c) some source material be included that is new, substantive, reliable, and independent of the subject. Vanamonde (Talk) 06:14, 25 August 2021 (UTC)[reply]

Ahanchian v Xenox Pictures Inc., et al

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Ahanchian v Xenox Pictures Inc., et al (edit | talk | history | protect | delete | links | watch | logs | views) – (View log)
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This U.S. Ninth Circuit Court of Appeals case does not appear to meet WP:GNG. My search on JSTOR, Google, and Google Scholar turns up citations of the case, but no in-depth summaries or analysis. I welcome any editors with access to a proper legal database like LexisNexis to search for additional sources that could establish notability. – Lord Bolingbroke (talk) 01:29, 18 August 2021 (UTC)[reply]

Note: This discussion has been included in the list of Law-related deletion discussions. – Lord Bolingbroke (talk) 01:30, 18 August 2021 (UTC)[reply]
  • Yes, there are many citations of the case, because the case laws which resulted from it are so important. In-depth summaries and analysis can also be found. Please give me a chance to edit this article and include them. Examples are [1], [2], [3]. Amirah talk 10:18, 18 August 2021 (UTC)[reply]
  • Comment – I don't want to mess up the AfD by moving the page midstream, but be aware: the correct title is "Ahanchian v. Xenon Pictures", with an "N" instead of an "X". If the page is kept, it should be moved to the correct title. Extraordinary Writ (talk) 18:07, 18 August 2021 (UTC)[reply]
  • Delete Not a particularly notable court case. KidAd • SPEAK 19:46, 18 August 2021 (UTC)[reply]
  • Keep The case is notable due to the case laws which resulted from it. The 'Good Cause' law which resulted from the case has been cited over 480 times in Federal Court Cases in the last decade, that's an average of 4x per month. There are also independent reliable sources which have published in depth analysis of the case. Citations for some of these have now been added to the article. The reason they are difficult to find is because of the huge number of sources about other cases which refer to the case laws created from the Ahanchian v Xenox case. [4]. Amirah talk 20:13, 18 August 2021 (UTC)[reply]
    @AmirahBreen: What gave you the idea that Ahanchian v Xenon Pictures established that four-factor legal test? If you would actually read the case, you would see that that standard was established in previous cases and the Ninth Circuit was just applying it to the particular details of Ahanchian's case. (It's also not a law, but rather a test; I'm not sure what led you to call it the "Good Cause law".) – Lord Bolingbroke (talk) 05:27, 19 August 2021 (UTC)[reply]
    Striking—AmirahBreen has !voted to draftify below. – Lord Bolingbroke (talk) 16:35, 23 August 2021 (UTC)[reply]
  • Delete without prejudice to re-creation if it ever becomes notable. I'm not impressed that it's been cited by other cases. The case is a decade old; it's a rare case indeed that doesn't get cited in that span of time.
And the fact that it was listed as a "top ten copyright case for November 2010"? That's not much of a distinction. I'm open to seeing some numbers, but I'm guessing of the twelve courts of appeal (1st-11th circuits plus federal circuit in the federal system; virtually none in the state systems) that hear copyright appeals, there are probably only twenty or so copyright cases each month. "Top ten in month foo" is not all that impressive, in context.
If and when it was written up significantly (not merely cited to) in, for example, law review articles, I would likely change my tune. TJRC (talk) 00:22, 19 August 2021 (UTC)[reply]
It has been written up significantly in law review articles, I have posted the links above, and they are in the article too. Amirah talk 00:27, 19 August 2021 (UTC)[reply]
It doesn't appear to have been. Of the links you posted:
[5]: routine news coverage
[6]; routine news coverage
[7]: law firm newsletter
[8]: mere citations without significant discussion in other cases (that's the "I'm not impressed that it's been cited by other cases" bit).
What law review articles can you cite to? TJRC (talk) 01:24, 19 August 2021 (UTC)[reply]
  • Add'l comment. I sampled the first 100 of the 480 cites from Google Scholar (the legal equivalent of WP:GHITS). Exactly one case (believe it or not, the 100th of the first 100 hits) is from outside the Ninth Circuit, which speaks to how non-influential this case is; virtually no courts outside of the case's home circuit have referred to it.
The one case from outside the Ninth Circuit is Ott v. Federal Home Loan Mortgage Corp., no. 12-2134 (6th Cir. 2013). Attorneys and law students reading this will note that there's no __ F.3d __ cite. That's not because I don't have it, it's because the Ott case is an unpublished case ("a decision of a court that is not available for citation as precedent because the court deems the case to have insufficient precedential value"). Ott (which is a one-page unsigned per curiam decision) cites Ahanchian for the unremarkable proposition that "A district court's decision as to a Rule 6(b) motion is reviewed for an abuse of discretion."
The longer I look into Ahanchian, the less notable it appears. TJRC (talk) 04:21, 19 August 2021 (UTC)[reply]
While I don't know of any Wikipedia policy against draftifying this, I strongly recommend against it; it's just going to be a waste of time. This is simply not a notable case, and it's never going to be accepted out of draft by anyone who understands the subject matter. If it somehow slips through, maybe by being reviewed by someone unfamiliar with law, it will end back up at AFD again. There's just nothing in here notable.
The article talks about a purported "Good Cause Law of Civility" that the case establishes, but there is no such thing. As Lord Bolingbroke points out, Ahanchian didn't even originate the four-factor test that AmirahBreen seems to think it did. A casual look at the case shows that Ahanchian cites a 1993 Supreme Court case (Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership, 507 U.S. 380 (1993)) for the pre-existing factors; and that case in turn goes back to another case, In re Dix, 95 B. R. 134 (9th Cir. 1982), which itself, according to Pioneer Investment, cited to In re Magouirk, 693 F.2d 948 (9th Cir. 1982), which presumably goes back even further.
The case stands for the unremarkable proposition, not very different from those present in a number of cases, that when, due to multiple extenuating circumstances, an attorney requests a one-week extension to file a paper from the other party, the other party should be a good guy and allow it; and even if he's a jerk and doesn't, the judge shouldn't dismiss the case for the late filing. This is an incredibly routine case. If it had been an affirmance rather than a reversal, I doubt it would even have merited an opinion.
By the way: looking at the subsequent history of the case (Amir Cyrus Ahanchian v. Xenon Pictures Inc et al, no. 2:07-cv-06295-JFW-E, C.D. Cal. Jan 12, 2011)) on PACER, it was settled and voluntarily dismissed by the parties, so it didn't go on to set any kind of precedent. Here's a docket extract:
  • 12/28/2010 155 NOTICE of Settlement filed by plaintiff Amir Cyrus Ahanchian. (Daar, Jeffery) (Entered: 12/28/2010)
  • 01/10/2011 156 STIPULATION to Dismiss Case pursuant to settlement agreement reached filed by plaintiff Amir Cyrus Ahanchian. (Attachments: # 1 Proposed Order)(Daar, Jeffery) (Entered: 01/10/2011)
  • 01/12/2011 157 ORDER by Judge John F. Walter. The court, having reviewed the Stipulation to Dismissal of Action With Prejudice 156 in the above-captioned action made by all parties, and finding good cause, that the above captioned action, United States District Court for the Central District of California Case No. CV 07-06295 JFW (Ex), entitled AMIR CYRUS AHANCHIAN, an individual, Plaintiff, vs. XENON PICTURES, INC., a California corporation; CKRUSH, INC., a Delaware corporation; SAM MACCARONE, an individual; PRESTON LACY, an individual; and DOES 1 through 10, inclusive, Defendants, shall be and is hereby DISMISSED IN ITS ENTIRETY, WITH PREJUDICE. (Made JS-6. Case Terminated.) (jp) (Entered: 01/12/2011)
I'd really encourage the creating editor to move along to an area that with which they are more familiar, and where they can more accurately assess the notability of the topics they're writing about. TJRC (talk) 21:27, 20 August 2021 (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.
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