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This is Jarvishunt, the article's creator. I would argue that 1) Federal judicial appeals-court nominations have become increasingly controversial, and Moreno is relevant because his name keeps being brought up (all throughout this decade) by U.S. Sens. Pat Leahy and Dianne Feinstein (google it to see) as one of 17 non-acted-on nominations in the latter part of Clinton's presidency; and 2) Moreno's notability isn't really in question, given that the "one event" that the guy is known for is a major political tussle in the upper house of a national legislature. I'm convinced that WP:ONEEVENT was intended for far more minor figures than this.
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