Wikipedia:Articles for deletion/Moxila A. Upadhyaya

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 keep‎. (non-admin closure) Actualcpscm (talk) 14:10, 9 August 2023 (UTC)[reply]

Moxila A. Upadhyaya[edit]

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While judges holding national office are presumed to be notable (WP:POLITICIAN), I am not sure that the same presumption can be taken to extend to United States magistrate judges, whose authority is much less than that of United States federal judges and whose duties are mainly administrative. In any case, the presumption, if it applies, is rebutted: I find no reliable independent sources covering Upadhyaya in any detail (WP:N). Google provides many hits, but they are passing mentions in which is reported that she e.g. administered the arraignment of this or that person. And the current minimal content is entirely a WP:BIO1E matter, reflecting her future (peripheral) involvement in the most recent indictment of Donald Trump. She is not the actual judge who will preside over his trial, and therefore future coverage of her and her decisions can be expected to as minimal as anything involving Trump can be. Sandstein 11:54, 2 August 2023 (UTC)[reply]

Note: This discussion has been included in the deletion sorting lists for the following topics: People, Law, Politics, and United States of America. Sandstein 11:54, 2 August 2023 (UTC)[reply]

Given that this is the first former president to face federal criminal charges, any judges involved in the process are ipso facto notable, administratively or otherwise. Furthermore, the future is unwritten. Today is August 2; the arraignment is tomorrow. Give it a day. kencf0618 (talk) 12:09, 2 August 2023 (UTC)[reply]

Agreed. ANY Judge involved in the possible conviction of Trump will be considered noteworthy to future historians. DO NOT DELETE. Deadvoodoo (talk) 01:47, 6 August 2023 (UTC)[reply]

Comment: The relevant notability criteria is here (for US judges). The individual is not de facto notable, but could still be notable. I'm pretty WP:MEH on keep vs. delete. Maybe their role in the Trump stuff is notable, maybe it's WP:TOOSOON. TulsaPoliticsFan (talk) 13:40, 2 August 2023 (UTC)[reply]

Delete Nom is correct that magistrate judges are not automatically notable, even if they are involved in a high-profile case. She is handling some procedural components before the district judge takes over, and unless there are independent sources about Upadhyaya herself, there is no basis for notability. A claim of "ipso facto notable" is false and has no basis in our guidelines. Reywas92^Talk 13:47, 2 August 2023 (UTC)[reply]
Note: This discussion has been included in the deletion sorting lists for the following topics: Women, Gujarat, and Missouri. Spiderone^{(Talk to Spider)} 20:42, 2 August 2023 (UTC)[reply]
Delete - recent independent and reliable coverage is limited, e.g. "Trump will make his first court appearance on Thursday before Magistrate Judge Moxila A. Upadhyaya. Such judges handle initial matters in federal cases." (ABC News); "NBC News reports that Trump will travel to Washington, D.C., on Thursday to be arraigned in U.S. District Court before Magistrate Judge Moxila A. Upadhyaya." (New York); "Trump won’t be placed under arrest, according to Wade. In accepting the indictment Tuesday, US Magistrate Judge Moxila Upadhyaya issued a summons for his appearance, not an arrest warrant." (Guardian, quoting Bloomberg). This seems to be "routine news coverage of announcements" that "is not by itself a sufficient basis for inclusion of the subject" according to WP:NOTNEWS. Similarly, other coverage includes e.g. anticipated work, i.e. hearing oral arguments, and submitting a report and recommendations to a federal district court judge for review (Bloomberg, Jan. 2023); delaying an arraignment and appointing a federal public defender (Reuters, Jan. 2023); granting a motion to delay a settlement conference (Bloomberg, Jun. 2023). She works on high-profile cases, but sources do not seem to offer secondary analysis or evaluation of her role to help support notability according to WP:BASIC/WP:GNG. The Wikiproject United States courts and judges WP:USJUDGE guidance says "Such judges are not inherently notable", but if an WP:NPOL presumption of notability exists for a magistrate judge, this seems rebutted here by a lack of sustained coverage from independent, reliable, and secondary sources. There are also nonindependent biographical materials from a former employer, e.g. [1], [2], [3], and a Bloomberg database profile, but these do not help support notability. Beccaynr (talk) 02:34, 3 August 2023 (UTC)[reply]

Just because Trump (or Beyonce or Zuckerberg) interacts with someone in an administrative capacity does not mean that they are notable. Think Clerk of the Court, bailiff who serves legal notices, policeman who escorts (and the command chains above them) Similarly tax auditors, notaries, etc, and in a health setting: nurses and non-lead doctors.

Apart from anything else, such people make no choice to be in the limelight and deserve not to be dragged into it, especially with the chance of fans of the famous person feeling aggrieved and seeking to harm them. Zsalya (talk) 16:45, 3 August 2023 (UTC)[reply]

Wikipedia has thousands of biographies of people who make no choice to be in the lime light. That is how encyclopedias tend to be written. CT55555(talk) 02:56, 4 August 2023 (UTC)[reply]

Keep This is a shameful and racist attack on the Honorable Ms. Upadhyaya. If she was not born in India this would not even be a discussion right now. She is clearly notable as her biography at the District Court says and all of these efforts to berate her and her character will fail. 2A01:CB10:9C1:B00:7D95:B89:5C5:79CF (talk) 18:12, 3 August 2023 (UTC)[reply]
Here is your precious source. Shame for assuming that just because she is from India she is not notable!

https://abcnews.go.com/Politics/magistrate-judge-moxila-upadhyaya-trumps-jan-6-case/story?id=101990791 2A01:CB10:9C1:B00:7D95:B89:5C5:79CF (talk) 18:14, 3 August 2023 (UTC)[reply]
Racism is a serious accusation. I don't see any racist attacks here. Please specifically identify what racism you see here. 331dot (talk) 19:28, 3 August 2023 (UTC)[reply]
Racism and prejudice are not always direct and point blank. Here the people are clever and do not directly mention Ms. Upadhyaya's place of birth but it is clear that they want her article deleted because of this and would not do the same for someone else 2A01:CB10:9C1:B00:1979:9196:7C33:303A (talk) 19:38, 3 August 2023 (UTC)[reply]
You state that the motives are clear but you've not offered any evidence to demonstrate that. Notability on Wikipedia is determined by whether there is significant coverage in independent, reliable sources, and the nomination focuses on exactly whether that test is met, as it would with any other nomination on the grounds of notability. Cordless Larry (talk) 20:04, 3 August 2023 (UTC)[reply]

You need to offer direct evidence of this, or withdraw the claim. You divining a meaning is not evidence. 331dot (talk) 23:41, 3 August 2023 (UTC)[reply]

No one in this discussion has suggested her birthplace makes her not notable. We examine available sources according the notability guideline. The ABC News source noted above cites her US District Court biography, and does not appear to add secondary support for notability. The NYT has similar coverage Who is the judge handling Trump’s initial court appearance?, noting "Judge Upadhyaya was appointed last year, and has handled proceedings for several Jan. 6 defendants", as well as a one-sentence summary of her past legal career; what a former employer says about her; her US District Court biography; and briefly noting political donations documented by OpenSecrets.
Another recent source (AP News) mentions "The arraignment will be handled before U.S. Magistrate Judge Moxila Upadyaha, who joined the bench last year"; the Guardian says "Thursday's hearing in the courthouse [...] was expected to be overseen by US magistrate judge Moxila Upadhyaya. Magistrate judges typically handle the more routine or procedural aspects of court cases, such as arraignments". She is not reported to have a substantial role in this Trump prosecution or other high-profile cases; recent coverage based on a brief burst of attention due to her proximity to this recent high-profile case therefore does not seem to offer substantial support for notability. Beccaynr (talk) 20:01, 3 August 2023 (UTC)[reply]
The valid discussion is of bias as being statistical, not individual: m:Community Insights/Community Insights 2023 Report#Race and Ethnicity in the US and UK. While "Asian or Asian American" US active Wikipedians are slightly overrepresented compared to their fraction of their population, "Asian or Asian British" UK active Wikipedians are underrepresented by a factor of two [here I'm ignoring uncertainties; if the sample size is the typical 1000 or so, then these "over-" and "under-" differences are statistically negligible (random effects only)]. See also racial bias on Wikipedia.
Of course, the IP editor alleging a "shameful and racist attack" is unhelpful, and verging on a personal attack, since attack is an allegation of negative intent, and shameful tends to imply intent too. Statistically racist behaviour as part of a group does not imply intent. Boud (talk) 02:34, 4 August 2023 (UTC)[reply]
Questions of how to handle the issue of statistically significant biases in Wikipedia are non-trivial; claiming deliberate intent is not acceptable (WP:AGF), except in the rare cases where that actually happens (not this case); claiming that the statistical biases are absent would be ignoring the RS'd evidence; trying to claim bias in an individual case doesn't make sense statistically. In any case, in this particular case there are plenty of sources over nearly two decades (see below). Boud (talk) 03:06, 4 August 2023 (UTC)[reply]
Thank you for this helpful insight. I might have been carried away with my words because racism (whether structural or intentional) really disheartens me and makes me want to speak out. I very much do hope that there was no actual negative intent 2A01:CB10:9C1:B00:AD3F:66A0:5052:8918 (talk) 09:00, 4 August 2023 (UTC)[reply]

Delete Trump comes in contact with many people. That fact alone does not make them "notable". — Preceding unsigned comment added by Mizrahim (talk • contribs) 02:11, 4 August 2023 (UTC)[reply]
Indeed "that fact alone" does not make her notable. But the significant coverage in reliable sources does. CT55555(talk) 02:53, 4 August 2023 (UTC)[reply]
Keep: I have sympathy for the argument to delete and I assume it was accurate when written, but the lack of significant coverage is no longer true, based on searches I did today. See:

https://abcnews.go.com/Politics/magistrate-judge-moxila-upadhyaya-trumps-jan-6-case/story?id=101990791
https://www.thehindu.com/news/international/indian-american-judge-moxila-upadhyaya-presides-over-trumps-appearance-in-federal-courthouse/article67156014.ece
https://www.nytimes.com/2023/08/03/us/politics/moxila-upadhyaya-trump-judge.html

Given the coverage is all recent, some might wonder if her notability for one event should preclude her, so also noting lots of brief mentions of her lawyering and judging, examples include:

Brief mention in 2019: https://georgetowner.com/articles/2019/02/04/whatever-happened-whole-foods/
Brief mention in 2023: https://www.reuters.com/legal/lockerbie-bombing-suspect-be-arraigned-us-federal-court-2023-01-25/
Historical society profile here: https://dcchs.org/sb_pdf/biographical-sketch-of-moxila-upadhyaya/

I think it is also important that she played a role in a historically significant event (today) so she is someone that encyclopedia readers may want to read about. Noting ~3,800 page views today, which appears to support that. Overall the presence of this article is a net positive to the encyclopedia. CT55555(talk) 02:17, 4 August 2023 (UTC)[reply]

The last source listed is not a historical society profile, it is the pdf in my first comment above - a biography produced by a former employer, so not independent. In my second comment above, I discussed the first and third sources listed - ABC News "Who is Magistrate Judge Moxila Upadhyaya in Trump's Jan. 6 case?" and the NYT "Who is the judge handling Trump’s initial court appearance?", and how they are not sigcov, due to a lack of independent and secondary content. The Hindu coverage repeats similar information and says "according to her resume" when discussing her work at Venable. The Reuters coverage of her delaying an arraignment and appointing a federal public defender is discussed in my first comment (WP:NOTNEWS, lack of secondary analysis or evaluation). The mention in The Georgetowner ("a free bi-weekly tabloid-style newspaper") of something she wrote as an attorney on behalf of a client also seems to be routine coverage. Beccaynr (talk) 02:54, 4 August 2023 (UTC)[reply]

I don't think WP:NOTNEWS precludes these sources because I don't think these profiles are "routine announcements", I think they are bona fide news articles and I think they have been written independently of the subject of the article. Yes, I see now that the historical society words are written by an ex employer, but it seems likely that the historical society made the decision that she was notable enough to publish it ("The Society is a tax exempt organization that operates independently from the courts"), so I think it counts for something (either way, it's not a core pillar of my keep !vote). CT55555(talk) 03:06, 4 August 2023 (UTC)[reply]

I think the brief mentions of her work over the past year as a magistrate judge is routine/NOTNEWS coverage - her work includes high-profile cases, but her role is limited, so it is not unexpected that coverage is limited. The recent profiles (generated because of a very high-profile arraignment) repeat a similar biographical overview that appears on her US District Court biography and do not seem to be multiple sources for WP:GNG - fn4 notes It is common for multiple newspapers or journals to publish the same story, sometimes with minor alterations or different headlines, but one story does not constitute multiple works. Several journals simultaneously publishing different articles does not always constitute multiple works, especially when the authors are relying on the same sources, and merely restating the same information. Even if the apparent recycling of her employer profiles could serve as one source, there still does not appear to be substantial support for WP:BASIC notability from other sources, including the Legal Times blog noted below, or awards from her employer or co-counsel. Beccaynr (talk) 04:02, 4 August 2023 (UTC)[reply]

Keep: passes WP:GNG as per the references given by CT55555. Three profiles in US and international media for the 3 August Trump appearance: The Hindu mentions the Mid-Atlantic Innocence Project awarded Judge Upadhyaya its Defender of Innocence Award in 2009 and Venable named her Pro Bono Lawyer of the Year in 2006; 2019 brief mention in Whole Foods vs Wical, brief mention 2023 Reuters, profile by Historical Society of the D.C. Circuit. Notable in 2008 as one of three lawyers who freed a man who had spent 20 years in prison for murder in a wrongful conviction. Boud (talk) 02:50, 4 August 2023 (UTC)[reply]
Keep. Quite a lot of news coverage now. If the judge doesn't stay notable, the article can be deleted then.--Mike Selinker (talk) 06:25, 4 August 2023 (UTC)[reply]
Notability isn't temporary, Mike Selinker. See WP:NOTTEMPORARY on this. Cordless Larry (talk) 09:13, 4 August 2023 (UTC)[reply]
Keep as she seems to have passed the WP:GNG threshold (possibly since this AfD nomination was made). Cordless Larry (talk) 09:15, 4 August 2023 (UTC)[reply]
Strong Keep Speaking as a decided Eventualist & Inclusionist (and the curator of this article), inasmuch as Judge Upadhyaya has set the terms of bail for Trump, she has authority over Trump. WP: Crystal Ball doesn't pertain; those are the facts of the matter. (P.S. I was mistaken; basically she set bail, and that was the end of her job.) kencf0618 (talk) 22:31, 5 August 2023 (UTC)[reply]
Keep. She has become a historical figure by arraigning the former President.Potsdamergänzer (talk) 12:53, 4 August 2023 (UTC)[reply]
Keep A month ago, there were not enough sources to pass WP:GNG. Today, however, there are. She's notable enough now. --Jayron 32 13:26, 4 August 2023 (UTC)[reply]
Keep per CT55555 and Boud. Passes WP:GNG. Sal2100 (talk) 17:55, 4 August 2023 (UTC)[reply]
Keep per WP:GNG.Classicfilms (talk) 20:42, 4 August 2023 (UTC)[reply]
Comment. There are ~~three~~ keep !votes over at Wikipedia talk:Articles for deletion/Moxila A. Upadhyaya CT55555(talk) 05:26, 5 August 2023 (UTC)[reply]
Keep. Adequate sources exist for GNG, and are cited in the article now. At the time its nomination, the article might have been a good candidate for deletion, but many of the RSs cited that meet GNG were published after it was nominated (since 2 August). If the article were nominated today, I surmise it would be a speedy keep.-Ich (talk) 10:46, 9 August 2023 (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.