# Talk:Abramski v. United States

I would like to upload the image found in the following link, however I was not able to draw a final conclusion to whether this is allowed under fair use from WP:IUP.

http://www.thefranklinnewspost.com/news/local/grand-jury-indicts-abramski-on-bank-robbery-counts/article_6eb7b033-01ac-5efd-9dc7-1c24d2192c4a.html
http://www.dailykos.com/story/2014/1/6/1261522/-What-Straw-Purchase-a-Gun-Abramski-v-US
http://www.dailykos.com/story/2014/6/3/1303838/-NOT-Breaking-News-SCOTUS-Continues-to-Deliberate-the-Straw-Purchase-Gun-Case
Thanks. WannaBeEditor (talk) 20:04, 29 February 2016 (UTC)

Sorry, but no, because it is evidently copyright to the Franklin News-Post, so it does not come under any of the four categories in WP:IUP#Copyright and licensing. It couldn't be "Fair use" because pictures of living people fail WP:NFCCP #1 "no free equivalent is available, or could be created". JohnCD (talk) 20:19, 29 February 2016 (UTC)

Hey guys, my first complete article. Any feedback is welcome. WannaBeEditor (talk) 02:41, 1 March 2016 (UTC)

Hi WannaBeEditor -- Thank you very much for taking the time to improve this article! Wikipedia is in desperate need of editors who are willing to write articles about United States Supreme Court cases (and all law articles, for that matter). I am very excited to see that you are willing to help. Of course, writing good content is one of the most difficult things to do on Wikipedia. I would like to offer a few comments with respect to writing articles about SCOTUS cases, and I hope these comments will help both this article as well as your future contributions to the encyclopedia:
Style and layout: For general information about formatting articles, see Wikipedia's manual of style at WP:MOS. Guidelines for formatting law-related articles can be found at MOS:LAW. There is also a style guide for writing articles about SCOTUS cases, which can be found at WP:SCOTUS/SG. I made a few stylistic changes to this article, but in general, you should make sure that articles comply with relevant style guidelines. You should also make sure that the formatting of the infobox complies with the directions that are listed at Template:Infobox SCOTUS case.
Introductory paragraphs: The introductory section of a Wikipedia article is called the "lead" (or "lede"). Relevant guidelines for writing lead sections can be found at WP:LEAD. In general, a lead section should provide the reader an overview of the article and why the topic is significant. Per WP:SCOTUS/SG, the very first sentence should explain the holding of the case. In the following sentences, I would then explain the factual background that gave rise to the case, a sentence or two about the court's ultimate ruling, and then explain the case's significance (see, e.g., the lead section at Reed v. Town of Gilbert).
Paragraph structure: In general, the purpose of a paragraph is to develop an idea that is expressed through sentences that build upon each other; paragraphs should use a strong topic sentence that introduces the reader to the topic that will be discussed in that paragraph, and the concluding sentence should tie everything together. Although there are plenty of articles that use one-sentence paragraphs, one-sentence paragraphs should be avoided (see WP:PARAGRAPHS). Instead, they should be incorporated with other paragraphs or expanded. Wikipedia's good article criteria requires articles to be "well-written," so it is important to make sure that prose is both readable and well-structured (see WP:GACR).
Citations: Per MOS:LAW, for articles about legal cases, it is recommended that editors use the citation style of the jurisdiction in which the case was heard. For SCOTUS cases, this will generally be Bluebook. However, it is important to keep the citation style consistent within the article (in fact, the GA criteria require consistency). That said, whenever you make a statement in the article about something that the Court said, held, our found, it is very important to include a citation to the page(s) of opinion to which you are referring (see relevant guidelines at WP:CITE). It is not sufficient to place a single citation to the opinion at the end of a paragraph, with no mention of the page(s) in the opinion that you are referencing.
Incorporating commentary and analysis: When developing articles about SCOTUS cases, it is essential to include commentary from scholars or other public response abut the case. This helps readers understand the case's significance and it is also an integral component of the breadth criterion at WP:GACR. However, it is important to present all perspectives per WP:WEIGHT (see also WP:NPOV) -- this is another important criterion for passing a GA review. Here, the commentary focuses on comments from the NRA. What have the NRA's opponents said about this? Also, for SCOTUS cases, it is particularly important to look at commentary that is published in law reviews (see, e.g., this commentary in the Harvard Law Review).
Please feel free to contact me if I can be of any help, but I want to emphasize how excited I am to see your contributions here. If you are interested in working on other law-related articles, you may also want to consider joining Wikipedia:WikiProject Law and Wikipedia:WikiProject U.S. Supreme Court cases. Both projects are a fantastic resource for editors interested in writing legal articles. In any event, thank you again for your hard work, and I look forward to working with you! Best, -- Notecardforfree (talk) 22:07, 2 March 2016 (UTC)
@Notecardforfree, thanks for the feedback and tips, will try to implement them in the future. WannaBeEditor (talk) 23:53, 2 March 2016 (UTC)
@WannaBeEditor: I would be happy to take on the review review for this article -- you are clearly a very talented editor and I think this article has a lot of potential. However, before beginning the review, I would ask that you first expand this article a bit (specifically, I would add background information about 18 U.S.C. 922 and expand the commentary/analysis section). Additionally, can you also add citations that include the specific page of the opinion that is being referenced (per WP:CITE)? Once that is done, feel free to ping me and I will begin the review. Best, -- Notecardforfree (talk) 19:41, 4 March 2016 (UTC)
@Notecardforfree:Thanks for volunteering, I will act on your suggestions. I will start doing so within a few day, when I am done with prior commitments. WannaBeEditor (talk) 20:23, 4 March 2016 (UTC)
Will start re-editing after the weekend. WannaBeEditor (talk) 17:03, 11 March 2016 (UTC)

This review is transcluded from Talk:Abramski v. United States/GA1. The edit link for this section can be used to add comments to the review.
Reviewer: AHeneen (talk · contribs) 09:31, 26 April 2016 (UTC)

I'm claiming this review. I will find time within the next two days to finish the review. AHeneen (talk) 09:31, 26 April 2016 (UTC)
@WannaBeEditor: I will (hopefully) have time to completely review this on Saturday. One thing that prevents this from being promoted is the citation style:

there is a bare link as a reference: http://conlawtest.sportsentertainmentattorney.com/2014/08/07/abramski-v-united-states-supreme-court-rules-straw-purchaser-gun-case/
 Done - WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
Ok. AHeneen (talk) 23:29, 2 May 2016 (UTC)
the citations to the Supreme Court decision use the pages in a reporter (eg. "Abramski, 134 S. Ct. at 2275"), but the link does not use those corresponding page numbers. That makes verification difficult. You could use the pages in the Supreme Court's slip opinion (see eg. Davis v. Ayala).
 Done - According to the Blue Book, when the official reporter is not available, the Supreme Court Reporter should be used. See this page. Accordingly, I simply chose to remove the link to LII, and remain with the citations to the reporter. WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
OK. I added a link to the SCOTUS slip opinion in the external links section. AHeneen (talk) 23:29, 2 May 2016 (UTC)
When citing a dissenting opinion, it should include "([surname of dissenting justice], J., dissenting)" (eg. "(Scalia, J., dissenting)").
 Done - WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
That was not done. AHeneen (talk) 23:29, 2 May 2016 (UTC)
Sorry, my mistake. Done now. WannaBeEditor (talk) 08:23, 3 May 2016 (UTC)
It's not clear what citation style this article is using. AHeneen (talk) 20:52, 29 April 2016 (UTC)

@AHeneen: I am not sure what you are referring to. If its the SCOTUS citations, the first is a regular Blue Book citations to the Supreme Court Reporter, the rest are short form citations. The other citations in the article use the standard cite web template. WannaBeEditor (talk) 21:32, 2 May 2016 (UTC)
That's the problem. The standard cite web template does not follow the BlueBook style. You need to change those references to Blue Book style as well. AHeneen (talk) 23:29, 2 May 2016 (UTC)
 Done WannaBeEditor (talk) 09:38, 3 May 2016 (UTC)

Thanks for accepting the review. Here is what I have done:

1b - @AHeneen: I don't see which part is not covered by the lead, can you please expound? WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
It doesn't cover the "Responses and analysis" or "Dissent" and it doesn't really discuss the background.AHeneen (talk) 23:29, 2 May 2016 (UTC)
2a -  Done - See comment on your comment above. WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
See my comments above. AHeneen (talk) 23:29, 2 May 2016 (UTC)
 Done WannaBeEditor (talk) 09:45, 3 May 2016 (UTC)
2c -  Done - WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
The phrase "and his house was searched by Federal agents who found the receipt." is still missing an inline citation. AHeneen (talk) 23:29, 2 May 2016 (UTC)
 Done WannaBeEditor (talk) 09:45, 3 May 2016 (UTC)
4 -  Done - WannaBeEditor (talk) 22:46, 2 May 2016 (UTC)
Ok. AHeneen (talk) 23:29, 2 May 2016 (UTC)

@WannaBeEditor: The only remaining issue with this article is that the lead does not adequately cover the entire article. It should include a sentence or two about both the dissent and the "Responses and analysis" sections. It also should mention just a little more about the "Factual background" of the case. You didn't respond above under my comment about the lead, so I was waiting for you to fix it...but since it's been a couple days without any edit, I just thought I should remind you in case you forgot. AHeneen (talk) 15:32, 5 May 2016 (UTC)

@AHeneen:Thanks, I will get to it today or tomorrow. WannaBeEditor (talk) 17:07, 5 May 2016 (UTC)
Sorry @WannaBeEditor:, I see that you haven't edited since the above comment. I hope you are OK. It has been two weeks, so it is time to close the nomination. You can renominate it later. If you do, leave a message on my talk page and I may do the review. AHeneen (talk) 01:52, 20 May 2016 (UTC)

@AHeneen: I was so busy didn't have time, but I have just finished editing the lead. Do I have to nominate it again? or can you still change the result?
WannaBeEditor (talk) 05:39, 22 May 2016 (UTC)

@Notecardforfree:, @AHeneen:, one of you still around?  Can you accept the review? Sorry about last time, just couldn't get to it in time. WannaBeEditor (talk) 05:07, 12 September 2016 (UTC)

WannaBeEditor, I can do the GA review -- I am pretty busy during the first half of this week but I can probably get started on Thursday or Friday. Best, -- Notecardforfree (talk) 08:56, 12 September 2016 (UTC)
@Notecardforfree: Thanks a lot. It should go pretty quick, I acted on all of the previous reviewer's suggestions, I just didn't complete the last one in time. WannaBeEditor (talk) 18:09, 12 September 2016 (UTC)

I think Kagan's authorship of the majority opinion and how the Justices voted should be integrated into the body of the article, not just the infobox. Knope7 (talk) 03:37, 15 September 2016 (UTC)

Knope7 - Good point, you can go ahead and do it per WP:BOLD, or I will do it when I get time. WannaBeEditor (talk) 03:49, 15 September 2016 (UTC)

This review is transcluded from Talk:Abramski v. United States/GA2. The edit link for this section can be used to add comments to the review.
Reviewer: Notecardforfree (talk · contribs) 20:31, 25 September 2016 (UTC)


### Comments/review from Notecardforfree
First and foremost, I want to apologize for not getting to this review sooner. My work has been incredibly busy this last month, but thankfully I had some free time this weekend. I think this article is very close to passing the Good Article Criteria. Please see below for items that need to be addressed before this article can be promoted. 


#### Well written
I made a number of copyedits, but feel free to revert any copyedits that you think are incorrect.
When referring to the Supreme Court of the United States, make sure you capitalize the "C" in "Court."
 Done - WannaBeEditor (talk) 21:04, 27 September 2016 (UTC)

I do, however, think the lead needs to be expanded to provide a complete summary of the article. Specifically, I think you need to add 3-4 sentences about the factual background and the majority opinion's reasoning (e.g. that straw arrangements are not part of the secondary market).
 Done - WannaBeEditor (talk) 22:25, 25 December 2016 (UTC)

In the "Opinion of the Court" section, you should explain that Justice Kagan wrote the majority opinion.
 Done - WannaBeEditor (talk) 21:12, 27 September 2016 (UTC)

Also in the "Opinion of the Court" section, I would recommend using a topic sentence as the first sentence in this section -- in that first sentence, you should summarize the Court's holding.
 Done - WannaBeEditor (talk) 22:36, 25 December 2016 (UTC)

Also in the "Opinion of the Court" section, I think the first sentence is a little misleading; Justice Kagan admitted that the act doesn't mention the term "straw purchasers," but Justice Kagan clarified that this is irrelevant to the ultimate inquiry because section 922 "looks through the straw to the actual buyer" (see slip opinion at p. 9). You offer some clarification in the next sentence, but you should make clear that the absence of the term "straw buyer" in the Act is irrelevant to the ultimate issue.
 Done - WannaBeEditor (talk) 22:37, 25 December 2016 (UTC)

Per WP:EL, I would remove the external links in the body of the "Opinion of the Court" section.
 Done - WannaBeEditor (talk) 21:16, 27 September 2016 (UTC)

Make sure terms and concepts are not wikilinked multiple times.
 Done - I removed all or maybe most of the duplicate wikilinks. WannaBeEditor (talk) 07:39, 5 October 2016 (UTC)

In the section about Justice Scalia's dissenting opinion, make sure to not say that Justice Scalia "held" anything. A dissent does not have the force of law, and thus is not a "holding." You can say he "would have held" XYZ or that he argued in favor of XYZ, etc.
 Done - Removed and rephrased all the "helds" in the dissent. WannaBeEditor (talk) 22:41, 25 December 2016 (UTC)


#### Verifiable with no original research
The first sentence of the "Opinion of the Court" section needs a citation (though see above for my recommendations about changing this sentence).
 Done WannaBeEditor (talk) 00:44, 15 February 2017 (UTC)

When citing to the Supreme Court opinion, make sure the citations include a range of pages if the material you are citing appears on multiple pages (see e.g. for footnote 16, which cites Abramski, 134 S. Ct. at 2277 (Scalia, J., dissenting)).
@Notecardforfree: I don't see your point, I believe that all the citations point to ranges of pages where applicable. I didn't review all of them again, but I remember being careful when first citing. In you example (which is now footnote 18 I believe) all the material appears in page 2277. That's the page where the dissent criticized the employment of agency law, though the dissent explained its application in the previous page. The discussion over "common English" and the conclusion that Abramski was the "person" are also contained in the same page. WannaBeEditor (talk) 00:58, 15 February 2017 (UTC)
@WannaBeEditor: I just took another look at this. I think the "agency" argument begins on p. 2276 in the paragraph that begins "The government maintains ...." and continues on the next page (where J. Scalia talks about "ordinary English usage in the interpretation of this criminal statute"). Aside from this one footnote, I think the other citations are correct. You are doing nice work on this article! -- Notecardforfree (talk) 01:39, 15 February 2017 (UTC)
 Done pointed to page 2276 as well. No point arguing this one out . . . WannaBeEditor (talk) 01:47, 15 February 2017 (UTC)

You need a citation for the claim that the case gained wide publicity (stated at the first sentence of the responses and analysis section).
 Done I removed it. Though it is pretty much self evident from the article I guess its considered original research. WannaBeEditor (talk) 02:11, 3 February 2017 (UTC)

It looks like you are using Bluebook style citations; make sure that all footnotes conform to relevant style guidelines (see this guide from Boston University). You can use the SMALLcaps template ({{smallcaps}}) where relevant. I would also recommend piping the external URLs to reduce clutter (see the citations in United States v. Drayton for an example of how this is done).
 Done I didn't pipe the links previously because it's not the blue book style per se, but I did now per your recommendation. I also applied the small caps where it was necessary. I didn't scrutinize thoroughly every citation, because I think I was relatively careful to include whatever possible and in the right format when first citing. Please point out if I made any mistakes. WannaBeEditor (talk) 01:42, 15 February 2017 (UTC)


#### Broad in coverage
In the background section, you should explain the difference between the primary and secondary market so that readers aren't surprised when they see the term for the first time in the "Opinion of the Court" section.
 Done - WannaBeEditor (talk) 02:25, 15 February 2017 (UTC)

I would say a little more about Kagan's arguments that Abramski's theory undermined the "core provisions" of the Act (see slip opinion at pp. 10-14)
 Done - WannaBeEditor (talk) 02:32, 16 February 2017 (UTC)

You may also want to include the "Deliverymen, after all, are not so hard to come by" quotation on p. 12 of the slip opinion.
 Done - WannaBeEditor (talk) 02:45, 16 February 2017 (UTC)

I would also expand your discussion of part III of Justice Kagan's opinion; you should say a little more about Abramski's "no harm, no foul" argument.
 Done - WannaBeEditor (talk) 05:11, 16 February 2017 (UTC)


#### Neutral
I wouldn't use the term "horrible injustice" in the lead-- I think this likely overstates the critics' concerns.
@Notecardforfree: It is John Lott's words quoted in the in Responses and analysis section.WannaBeEditor (talk) 07:44, 5 October 2016 (UTC)
I stand corrected, though I did place the phrase "horrible injustice" in quotation marks to reflect the fact that Lott used the phrase. -- Notecardforfree (talk) 21:09, 5 October 2016 (UTC)
In the "Supreme Court" section, you summarize the views of the views of the NRA's amicus brief. Per WP:WEIGHT you should also include the views of the other Amicus briefs; this would probably work best if you presented a general summary of arguments that were shared by multiple different amici.
 Done - I just added Brady Center's brief as a counter balance, I don't think an expanded discussion is really necessary. WannaBeEditor (talk) 02:51, 15 February 2017 (UTC)


#### Stable
There are no issues with stability.


#### Illustrated with images
Per usual Wikipedia convention for SCOTUS articles, I would recommend including a picture of Justice Kagan.
 Done - WannaBeEditor (talk) 20:59, 27 September 2016 (UTC)


#### Other comments not relevant to the GA criteria
In the first sentence of the lead, the article provides a sentence that describes part of the underlying factual background. I would recommend using the very first sentence to explain the case's holding or significance. Maybe you can say something like "Abramski was a case in which the Supreme Court of the United States held that a gun buyer cannot purchase a firearm on behalf of another" or something like that. Then in the next sentence you can say "the case arose when a former police officer from Virginia bought ...."
In general, I strongly encourage you to consolidate short paragraphs, and I also strongly recommend that you do not use single-sentence paragraphs. The purpose of a paragraph is to develop an idea or a topic; related sentences should be grouped together within the narrative structure of a single paragraph.
 Done - WannaBeEditor (talk) 02:41, 16 February 2017 (UTC)
Please let me know if you have any questions about any of these points. I will place this review on hold until the issues are resolved, but most of these are rather minor issues and I am confident that it won't take too much time to resolve them. Best, -- Notecardforfree (talk) 20:31, 25 September 2016 (UTC)
@WannaBeEditor: you may have already received a notification on your watchlist, but I am giving you a courtesy ping to let you know this review is underway. I should also mention that my comments should not be construed as criticism of the incredible work you have done to write this article; you have clearly put a lot of hard work and many hours of research into this, and I commend your efforts. Wikipedia is certainly in need of editors who cover legal topics, and I hope you keep up the good work! Best, -- Notecardforfree (talk) 20:47, 25 September 2016 (UTC)


### Query
Notecardforfree, WannaBeEditor, where does this nomination/review stand? As far as I can tell, the last work done to the article and to this review page were both on October 5, 2016, over three weeks ago. Thanks. BlueMoonset (talk) 07:26, 29 October 2016 (UTC) 

BlueMoonset- got so busy that I just couldn't get to it. I won't really have time until December. WannaBeEditor (talk) 00:02, 30 October 2016 (UTC)
WannaBeEditor and BlueMoonset, I'd be happy to keep this review open through December; I think it makes more sense to continue the current review than to start one from scratch. I'm certainly in no rush (WP:NODEADLINE). Best, -- Notecardforfree (talk) 03:33, 30 October 2016 (UTC)
@Notecardforfree: Thanks, I think it makes sense too. BTW did you see my last email? WannaBeEditor (talk) 04:33, 30 October 2016 (UTC)
@WannaBeEditor: I did, and I just sent you a response. In terms of finishing this review, feel free to ping/email me whenever you want me to take another look at things. Best, -- Notecardforfree (talk) 21:13, 30 October 2016 (UTC)
@Notecardforfree and WannaBeEditor: has there been any progress on this nomination? Wugapodes [thɔk] [ˈkan.ˌʧɻɪbz] 20:13, 12 December 2016 (UTC)

@Wugapodes: Will get to it really soon, please leave it be for now. Thanks. WannaBeEditor (talk) 20:55, 12 December 2016 (UTC)
Don't worry, I won't touch a thing. Just wanted to make sure it wasn't forgotten about. Wugapodes [thɔk] [ˈkan.ˌʧɻɪbz] 21:38, 12 December 2016 (UTC)
Notecardforfree, WannaBeEditor, I see a handful of edits on December 25, but nothing in the three weeks since. Where does this stand, and is sufficient progress being made? This has been open for over three and a half months now, which unusually long. BlueMoonset (talk) 22:53, 16 January 2017 (UTC)
BlueMoonset, thanks so much for checking in (and for all your other amazing efforts at GA). I have been in contact with WannaBeEditor, and I can confirm that sufficient progress is being made. We are making steady improvements here, and I am in no rush to close this while enhancements are forthcoming. All the best, -- Notecardforfree (talk) 18:42, 17 January 2017 (UTC)


### Final comments
WannaBeEditor, you have done fantastic work with this article! I am pleased to announce that it satisfies all GA criteria, and I am going to go ahead and close this as a passing review. Thank you very much for your strong work, and I look forward to reading more of your contributions in the future. All the best, -- Notecardforfree (talk) 18:18, 16 February 2017 (UTC)

Notecardforfree - Thanks. WannaBeEditor (talk) 17:48, 17 February 2017 (UTC)