Talk:Hertz Corp. v. Friend

not required for GA, but nice to have

• maybe include footnotes on the bullet point list with case citations, so readers can see which cases led to each circuit adopting its particular test? theleekycauldron (talk • she/her) 22:47, 29 September 2025 (UTC)

GA review – see WP:WIAGA for criteria

1. Is it well written?

   A. The prose is clear and concise, and the spelling and grammar are correct:

   I copyedited each section. Feel free to identify your points of disagreement as replies here or revert changes you disagree with. In the latter scenario, if I think I am right over a grammar rule, rather than a grammar suggestion, then I will offer a rebuttal here.

   B. It complies with the manual of style guidelines for lead sections, layout, words to watch, fiction, and list incorporation:

   MOS:INTRO advises to make the lead section accessible to as broad an audience as possible, so I understand why you have the intro refer to the Judiciary Act of 1789 instead of 28 U.S.C. § 1332 even though, as you explain in the "Background" section, the relevant language on a corporation's state citizenship was added way later by the 1958 Act Amending the Jurisdiction of District Courts in Civil Actions With Regard to The Amount in Controversy and Diversity of Citizenship. That being said, the lead sentence Diversity jurisdiction, described in the Judiciary Act of 1789, allows federal courts to hear cases on state law if the parties are "citizens" of different states; a corporation's citizenship is determined based on its principal place of business and where it is incorporated. heavily implies that the modern definition of corporate state citizenship existed in 1789 since the sentences are joined by a semicolon. I think the second half should be fully split with a period and read, "Since 1958, a corporation's citizenship has been determined based on its principal place of business and where it is incorporated." while continuing to use "Judiciary Act" as a stand-in for § 1332 throughout the article.

   MOS:EMBED dictates that Embedded lists should be used only when appropriate; sometimes the information in a list is better presented as prose. I agree that a bulleted list is the best format for the circuit split, but I think it is unnecessary to have a first list explaining the three tests and then a second list explaining how those tests and their variations were adopted by the circuits. It seems best to combine them with bullets like "The Seventh Circuit used the nerve center test, which designated the state from which the corporation's officers direct its activities as its principal place of business."

    Done ViridianPenguin🐧 (💬) 06:19, 29 November 2025 (UTC)

2. Is it verifiable with no original research, as shown by a source spot-check?

   A. It contains a list of all references (sources of information), presented in accordance with the layout style guideline:

   B. Reliable sources are cited inline. All content that could reasonably be challenged, except for plot summaries and that which summarizes cited content elsewhere in the article, must be cited no later than the end of the paragraph (or line if the content is not in prose):

   Per WP:CITEDENSE, there is no requirement to have a citation at the end of each paragraph, but in the four instances of paragraphs ending without a footnote, I am unsure what the respective claims are being sourced to. Before I proceed with a citation spot-check, I am putting this review on a 7-day hold to give you a chance to add the appropriate indicators of sourcing.

    Done ViridianPenguin🐧 (💬) 06:19, 29 November 2025 (UTC)

   C. It contains no original research:

   Checked 15% of the sources, and per the table below, all six supported their associated claims. ViridianPenguin🐧 (💬) 06:44, 29 November 2025 (UTC)

   D. It contains no copyright violations nor plagiarism:

3. Is it broad in its coverage?

   A. It addresses the main aspects of the topic:

   B. It stays focused on the topic without going into unnecessary detail (see summary style):

   My only complaint is that the final two sentences on Sri Srinivasan end the article on a whimper of trivia instead of the preceding interesting commentary on the future of corporate personhood. My suggestion is that after The court held oral arguments on the case on November 10, 2009., you should have a single sentence like "Sri Srinivasan argued on behalf of Hertz and was later appointed to the U.S. Court of Appeals for the D.C. Circuit, currently serving as its Chief Judge". I see no need to mention Todd M. Schneider as opposing counsel since a) he lost and b) he is not notable by Wikipedia standards. Otherwise, wonderful writing, especially in really digging at the ways this case produced a business-friendly outcome!

    Done ViridianPenguin🐧 (💬) 06:19, 29 November 2025 (UTC)

4. Is it neutral?

   It represents viewpoints fairly and without editorial bias, giving due weight to each:

5. Is it stable?

   It does not change significantly from day to day because of an ongoing edit war or content dispute:

6. Is it illustrated, if possible, by images?

   A. Images are tagged with their copyright status, and valid non-free use rationales are provided for non-free content:

   B. Images are relevant to the topic, and have suitable captions:

   Wonderful job creating the map on pre-Hertz "principal place of business" tests! A picture is worth a thousand words and in this case, it visualizes the circuit split much easier than the 128-words of the Background section's bullet list.

7. Overall:

   Pass or Fail:

   @Eithersummer: I will keep this review on hold until at least 02DEC2025 for you to resolve the in-line sourcing issue noted above and respond to the other points. Let me know if you need additional time!

   Passes all the criteria! ViridianPenguin🐧 (💬) 06:44, 29 November 2025 (UTC)

For some reason I can't reply to your section directly so I will write my reply here:

• Copyediting: I have no objection to any of the copyedits
• Intro: Changed accordingly.
• List: Combined list.
• Cite paragraphs: Added cites, including some new sources. Previously the uncited paragraph ends would have been sourced from the fn in the following paragraph.
• Srinivasan: moved up to the oral argument section. Eithersummer (talk) 03:09, 27 November 2025 (UTC)

Yeah, I struggle to understand why the VisualEditor option to reply is not available on all types of threads. I think installing User:Novem Linguae/Scripts/VisualEditorEverywhere.js should give you that option, but otherwise, you have to reply using the source editor. :( Thanks for handling three of the four instances where a paragraph ended without a footnote. Per your reply, I have confirmed that in the remaining instance, the subsequent footnote supported the material and accordingly appended that footnote to the preceding paragraph. I will proceed with the citation spot-check now. ViridianPenguin🐧 (💬) 06:19, 29 November 2025 (UTC)

This table checks 6 passages from throughout the article (15.8% of 38 total passages).

These passages contain 6 inline citations (15.4% of 39 in the article). Generated with the Veracity user script. ViridianPenguin🐧 (💬) 06:44, 29 November 2025 (UTC)

More information Reference #, Letter ...

Reference #	Letter	Source	Archive	Status	Notes
The Judiciary Act of 1789 grants federal courts the ability to hear cases concerning state law (as opposed to federal law) under a limited set of circumstances, with the case otherwise heard in state court. One of these circumstances is "diversity jurisdiction", where the parties in the case are "citizens" of different states.
1		doi.org
In January 2008, the district court granted the motion to remand. Applying the Ninth Circuit's place of operations test, it found that Hertz was a citizen of California because the large plurality of the company's business activities were performed in California. Since the plaintiffs (and by definition the class members) were also Californians, this meant that the district court did not have diversity jurisdiction and had no authority to hear the case. Hertz, claiming to be a citizen of New Jersey and Delaware (where it is incorporated), argued that the test should be adjusted for population since California has a much larger population than any other state, but the district court was unpersuaded. Hertz appealed the case to the Ninth Circuit, arguing that the district court had misapplied the test.
13	b	papers.ssrn.com
represented Hertz in oral arguments.
18		courthousenews.com	web.archive.org
Breyer first noted that the phrasing of the term "principal place of business" implied that the citizenship of a corporation depended on a single location rather than a spread-out area, favoring the nerve center test.
26		search.worldcat.org
Breyer wrote that the test was not perfect, stating that in some cases officers may be in many different locations and that "anomalies" could result if a company's nerve center and business activities were in different states.
30		bowmanandbrooke.com
Attorney John T. Mitchell wrote in GPSolo Magazine that Hertz, in recognizing that corporations had a "brain", represented a step in their gradual humanization, comparing it to Citizens United v. FEC, which had also been decided in 2010. He also criticized the decision for allowing inexact results, particularly in the age of teleconferencing, and being unclear as to when an executive performs "nerve center activity".
39		search.worldcat.org

Close

theleekycauldron

• is marc robertson a subject-matter expert? [may chime in with more later, just on a cursory scroll] theleekycauldron (talk • she/her) 05:19, 25 May 2026 (UTC)

  I don't think he is an expert on legal education or diversity jurisdiction, but I think he has the requisite general knowledge to say that Hertz is taught in law school. He wrote the Forbes article on behalf of the Washington Legal Foundation and according to Legistorm he worked at the House Judiciary Committee, so he is 100% a lawyer. Plus he got his JD after 2010 so he has to have learned Hertz. Eithersummer (talk) 19:08, 25 May 2026 (UTC)

1brianm7

Could you check the first paragraph for understandability? It took me like a minute to read it and understand it (I think?) and the comma and colon are used in ways that don't seem particularly natural to me. The first sentence is 40-words. 1brianm7 (talk) 09:19, 8 June 2026 (UTC)

Z. Patterson

I have some questions and points about the article.

• Are the quotes in the lead important? Can you try a paraphrase or summary instead?
• Per WP:FACR criterion 2c, try to make the citations as consistent as possible. If you have optional identifiers in one citation, then the other citations should also have the same identifiers, unless you are unable to provide them. Please see Rei Ayanami as an example of an article with comprehensive citations that try to be as consistent as possible.
• Why is a news article being cited for footnote b? Can you find an academic monograph or peer-reviewed journal article to replace the news article in footnote b? Repositories such as HeinOnline may be able to provide better sources. I encourage you to use the Wikipedia Library.
• Can you try to reduce your reliance on quotations and try to paraphrase and summarize in the body? I am sure featured article candidate reviewers may point this out.
• Can you try to replace Forbes with a peer-reviewed journal article or academic monograph? You can try to look in HeinOnline, as an example.
• Titles of court cases need to be italicized, even in citations.
• You may wish to look at footnote c and determine if you need to put a citation in for that footnote.

Even the most minute details will matter at an FAC, so I encourage you to consider these questions and points about the article. Z. Patterson (talk) 03:18, 16 July 2026 (UTC)