Source: qa/cases-QA2.md
# QA2 review — CASE DSL sample Reviewed the even-numbered `.case` files in sorted filename order within each of the five statute directories (6 per statute, 30 total). Compared the annotated facts, rules, holdings, and variant labels with the pinned IR opinion text and the case summaries in the files. Ran the CASE DSL checker on the full corpus; all 60 files and 1,172 quotes passed with zero errors. `FIX` means the current case annotation has a material label/holding/citation-role mismatch to correct. Structural limitations that are already accurately documented in the case's `misfit` lines do not by themselves make the file fail. ## Per-file verdicts ### 15 U.S.C. § 1 - **PASS** — `f-supp-3d-351-698-in-re-interest-rate-swaps.case` (In re Interest Rate Swaps): the two pleaded agreement holdings track the survival ruling and their variants describe the parallel-platform boycott and joinder theories. The rejected law-of-the-case argument is awkwardly stored as a defense, as the file itself flags; the court's limitations ruling is deferred, not rejected. - **PASS** — `f2d-361-874-ford-v-websters-auto-sales.case` (Ford v. Webster's Auto Sales): correctly separates vertical agreements from the unsupported horizontal theory and ties the per-se holding to the vertical arrangement. The dated doctrine and the [proved] basis for the failed horizontal theory are appropriately flagged as limitations. - **PASS** — `f2d-845-1367-us-v-cooperative-theatres.case` (United States v. Cooperative Theatres): agreement sufficiency and the customer-allocation per-se holding match the opinion. The intent label captures the limited holding that knowledge of probable anticompetitive effects was unnecessary; it should not be read as a freestanding factual finding. - **FIX** — `f3d-496-403-tunica-web-advertising-v-tunica-casino-operators.case` (Tunica Web Advertising): `standing : not-satisfied [conceded]` reports the district court's unchallenged ruling as if the panel decided the element. The appeal expressly does not review Graziosi's standing ruling; mark it as a lower-court disposition/not reached for this panel, or otherwise scope it to the lower court. The per-se block is correctly marked not-reached because the panel corrected the test but remanded its application. - **PASS** — `us-550-544-bell-atlantic-v-twombly.case` (Bell Atlantic v. Twombly): the two parallel-conduct variants and not-satisfied pleading holdings accurately reflect the complaint's failure to make agreement plausible. The broader Rule 8 consequence and absence-fact limitations are accurately noted. - **PASS** — `us-560-183-american-needle-v-nfl.case` (American Needle): the distinction between teams acting separately and the jointly owned NFL Properties entity matches the Court's functional single-entity analysis. Treat the opinion as selecting the rule for analysis, not finally finding the § 1 merits violation. ### 18 U.S.C. § 1962 - **PASS** — `f-supp-2d-926-1143-negrete-v-allianz-life.case` (Negrete v. Allianz Life): the enterprise/person and pattern theories follow the opinion's analysis; the file flags the relation-versus-element problem. - **PASS** — `f2d-624-1118-united-states-v-weisman.case` (United States v. Weisman): accurately records the pre-*H.J. Inc.* relatedness rule and the alternative holding. The superseded doctrine and jury-instruction review are explicitly called out as temporal and holding-type limitations. - **FIX** — `f3d-490-575-united-states-v-calabrese.case` (United States v. Calabrese): `enterprise : satisfied [pleaded]` overstates the decision. The court did not decide whether an enterprise existed; it provisionally treated the charged parent Outfit as different from earlier street-crew enterprises for double-jeopardy purposes. The file's gloss recognizes the distinction, but the holding label still asserts an element finding. - **PASS** — `f3d-80-1293-chang-v-chen.case` (Chang v. Chen): the separate-structure failure and continuing-unit success match the two-prong pleading analysis. Its now-superseded test is clearly disclosed. - **FIX** — `us-510-249-now-v-scheidler.case` (NOW v. Scheidler): `commerce : satisfied [law]` asserts that the commerce element was met, but the Supreme Court decided only that § 1962(c) contains no economic-motive requirement; it expressly did not determine whether the alleged conduct met the commerce nexus. Recast this as a rule/no-motive holding and leave application not reached. The injury block also describes Article III standing, not § 1964(c)'s business-or-property injury, as its gloss acknowledges. - **FIX** — `us-556-938-boyle-v-united-states.case` (Boyle v. United States): `enterprise : satisfied [proved]` makes an evidence-sufficiency claim the Supreme Court did not decide. The holding was that the jury instruction correctly stated the association-in-fact test; the Court did not review sufficiency of the evidence. The variant's fact pattern is apt, but the holding kind/basis needs correction. ### 21 U.S.C. § 841 - **FIX** — `f-supp-3d-225-274-us-v-tiangco.case` (United States v. Tiangco): the `quantity : satisfied [proved]` block quotes the jury's conspiracy-wide quantity finding on Count 1, then glosses the separate 55 g parcel on Count 2. Since those quantities concern different counts and the parcel quantity was not itself found by the jury, the block needs a count-specific scope or should be removed from the § 841 Count 2 instance. Other distribution/venue holdings are accurately identified as alternative routes. - **FIX** — `f2d-779-1098-united-states-v-prieto-tejas.case` (United States v. Prieto-Tejas): the variant `conspiracy-846/tacit-agreement-inferred-from-joint-transport` is stored under § 841 `aiding`. It concerns a separate § 846 conspiracy offense, not aiding liability under § 841; the misfit notes the missing § 846 model, but the present element/variant placement is materially misleading. - **PASS** — `f3d-235-565-us-v-hishaw.case` (United States v. Hishaw): distinguishes failure to establish the aggravated quantity threshold from the harmless-error/lower-tier sentence holding. The court's reliance on uncontested evidence rather than a jury quantity finding is disclosed. - **PASS** — `f3d-767-453-us-v-teran-salas.case` (United States v. Teran-Salas): correctly labels the § 841 material as a categorical comparator rather than a prosecution under § 841. The `x-categorical-match` workaround is visibly identified as such. - **PASS** — `us-500-453-chapman-v-united-states.case` (Chapman v. United States): the quantity block faithfully describes the statutory carrier-medium rule in a sentencing-threshold case, and separates the constitutional/canon arguments from guilt under § 841(a). - **PASS** — `us-571-204-burrage-v-united-states.case` (Burrage v. United States): accurately captures the but-for causation rule and reversal where the government could not prove the victim would have lived without the drug. The penalty-tier/death-results distinction is flagged. ### 42 U.S.C. § 1983 - **PASS** — `f-supp-567-1159-thompson-v-community-action.case` (Thompson v. Community Action): separates entity state-actor status from the lack of a state nexus to the challenged employment action; the split prongs and non-§ 1983 Fifth Amendment claim are flagged. - **PASS** — `f2d-628-1104-dodson-v-polk-county.case` (Dodson v. Polk County): the panel's then-existing holdings are represented, and the report explicitly warns that the color-of-law holding was later reversed by the Supreme Court. Qualified-immunity `satisfied` means defense availability rather than success, a limitation correctly called out in the gloss. - **PASS** — `f3d-475-645-johnson-v-caudill.case` (Johnson v. Caudill): distinguishes no equal-protection violation on some incidents from qualified-immunity protection on others; the incident-specific and two-prong QI limitations are noted. - **PASS** — `f4th-141-417-galloway-v-county-of-nassau.case` (Galloway v. County of Nassau): the fair-trial theories and qualified-immunity outcomes track the majority's dispositions. The file warns that the merits holdings are largely inherited from the district court and that the opinion's dissent and flattened slip text complicate quote interpretation. - **PASS** — `us-503-1-hudson-v-mcmillian.case` (Hudson v. McMillian): accurately reports that minor injury does not bar the excessive-force claim and that the on-scene supervisor's conduct was supported by an undisturbed finding. The missing constitutional-right model and reserved question are documented. - **PASS** — `us-526-40-american-manufacturers-v-sullivan.case` (American Manufacturers Mutual Insurance v. Sullivan): correctly distinguishes private insurers from public officials and records the state-action and property-interest rulings. Fractured-opinion alignment and Lugar's separate prongs are flagged. ### 42 U.S.C. § 2000e-2 - **PASS** — `f-supp-2d-832-539-glenn-v-raymour.case` (Glenn v. Raymour): comparator differences, alternative pretext ruling, and abandoned claims match the opinion. Abandonment is accurately disclosed as procedural rather than a merits holding. - **PASS** — `f-supp-962-1447-breech-v-alabama-power.case` (Breech v. Alabama Power): disparate-treatment, accommodation, and retaliation holdings match the opinion. The separate accommodation theory and alternative burden-shifting stages are flagged; the no-evidence basis is used for adverse summary-judgment findings. - **FIX** — `f3d-41-1073-eeoc-v-francis-w-parker-school.case` (EEOC v. Francis W. Parker School): this is an ADEA claim, not a Title VII case. Section 2000e-2(a)(2) is comparator text only; the current element block attaches the ADEA holding and facts to a Title VII `impact` block. Keep it out of the § 2000e-2 instance or represent the citation role as comparator/analogy. - **PASS** — `f3d-858-1307-hiatt-v-colorado-seminary.case` (Hiatt v. Colorado Seminary): the assumed prima facie case, action-specific adverse-action outcomes, and pretext rulings are consistent with the opinion. It clearly identifies the mismatch between Title VII/Title IX and the flat element-stage model. - **PASS** — `us-510-17-harris-v-forklift-systems.case` (Harris v. Forklift Systems): the Supreme Court rejected a psychological-injury requirement and remanded application of the proper hostile-environment standard; the not-reached label accurately signals no ultimate application holding. - **FIX** — `us-557-557-ricci-v-destefano.case` (Ricci v. DeStefano): the `court` header identifies the Second Circuit although this is the Supreme Court opinion. Also, the `impact`, `impact.business-necessity`, and `impact.alternative` blocks describe a hypothetical disparate-impact defense to the disparate-treatment claim, not adjudicated elements of an actual § 2000e-2(k) claim. The file's misfit explains the inversion but the present element labels can be consumed as actual claim findings. Correct the court metadata and explicitly scope these blocks as hypothetical defense analysis. ## Overall assessment The notation is usable as a human-reviewed index of element-level reasoning when the cited statute is actually applied and the case decides the element on the merits. Exact source quotes, offsets, and the `misfit` escape hatch make review reproducible. It breaks when a citation is only a comparator or analogy, when the opinion states a rule without applying it, when a holding concerns a procedural stage or hypothetical claim, or when doctrine is nested across elements, parties, counts, theories, or multiple opinions. In this sample, the `FIX` cases show that explanatory misfit prose does not prevent an incorrect element/holding label from being ingested downstream. The next version should make citation role and opinion/case scope explicit, distinguish rule announcements and hypothetical/alternative holdings from element application, and type the party/count/theory qualifiers. Preserve the existing quote-verification contract. Verification: `python3 neov2/tools/casedsl.py check neov2/cases` — 60 files, 1,172 quotes, 0 errors. No `.case` files or corpus source text were edited.