It certainly would have in the Freshman Composition one I taught at the University of Michigan at Ann Arbor, Michigan.
That's because some of the content has been plagiarized. For example, some wording had been copied from an Indiana Law Journal without attribution. Here are more of the details in the Bloomberg article by Noah Feldman.
Plagiarism is plagiarism. That the whole book isn't a major lift from others' work isn't relevant.
What Gorsuch did should be held against him. After all, he is a trained lawyer. That field requires total documentation. He isn't a Don Draper from "Mad Men" who has creative license in presentation style.
The reasons proofreaders in BigLaw are paid so well is that they must catch everything, ranging from typo to missing punctuation in a citation. That's the ethos Gorsuch supposedly embraced when he was admitted to the bar.
For this, I would "Bork" him in his quest to be confirmed as a justice of the U.S. Supreme Court. End of that story.
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