Table of Contents:
Introduction
On January 2nd, 2024, Claudine Gay stepped down from her role as President of Harvard University following a series of allegations that she had committed plagiarism throughout her academic career (Egan 2024). These allegations spurred online discourse which can only be accurately described as a dumpster fire:
The purpose of this essay is not to add fuel to this fire but to instead take a step back and ask a much more fundamental question which should have been asked at the very start of this discourse: why is plagiarism wrong?
By exploring the merits of various answers to this question, I aim to provide an account of the wrongness of plagiarism which can then be used to normatively evaluate the actions of plagiarists.
What This Essay Must Do
Before we can review the soundness of answers to the “why is plagiarism wrong” question, we need to first articulate what criteria must be satisfied by a proper account of the wrongness of plagiarism. Drawing on Harvard College Writing Program (2023), I argue that such an account must satisfy the following:
It must explain the wrongfulness of conceptual plagiarism: the usage of ideas that were originally conceived by another without proper attribution.
It must explain the wrongfulness of linguistic plagiarism: the act of copying language expressed by others without proper attribution.
It must explain the wrongfulness of self-plagiarism: the failure to properly cite one’s own prior work.
It must explain the common knowledge exemption: the view that certain ideas and facts are so well-known that they need not be cited
With these criteria on the table, we can now review the ethical arguments against plagiarism and identify which, if any, make the cut.
Harm To The Author
The harmed author argument asserts that plagiarism is wrong because it harms the author whose work has been plagiarized. This harm occurs because the victim is denied the opportunity to bolster their reputation in the academic community since the plagiarist has taken credit for their work.
Though the argument is intuitively appealing, it has the rather peculiar implication that plagiarism is morally acceptable when the victim is not harmed by the plagiarist (i.e. the victim sees little wrong with the plagiarist’s actions).
This implication creates serious issues in cases where the target of plagiarism harbors a warped perspective (perhaps due to the institutional prestige of the plagiarist).1 To see why, we can consider the analogous case of cheating:
Misty and Ash are both close friends taking a multiple-choice exam. Halfway through the exam, Misty looks to her left and notices Ash furiously copying down the answers she had bubbled in just minutes earlier. While she is initially appalled, she decides not to inform the professor. “After all, he won’t pass this class unless he does well,” she thinks to herself. Later that day, both students are elated to learn that they aced the exam.
The thought experiment illustrates that the wrongfulness of an action (and subsequent punishment) cannot solely depend on whether action’s target deems it to be acceptable. We do not excuse Ash’s cheating merely because Misty believes it to be acceptable. Likewise, we cannot excuse the plagiarist’s behavior merely because the target claims to be unharmed. Doing so would be tantamount to entertaining the academic analogue of Stockholm syndrome.
A defender of the harmed author argument might respond by claiming that harm to the author is a sufficient condition of the wrongfulness of plagiarism. This amendment is perfectly acceptable but it ultimately raises an interesting question: why is plagiarism wrong even when the target deems it acceptable?
Scholarly Scrutiny
The scholarly scrutiny argument asserts that plagiarism is wrong because it deprives the scholarly community of the ability to appropriately scrutinize a piece of academic work. The intuition behind the argument can be made apparent through the following thought experiment:
Grisha is writing a book on the history of the Eldian Empire. He scours through a number of archival sources, concludes that the Empire yielded a net-positive impact on humanity, and shares the book with the press. But in his haste to publish, he accidentally forgets to accompany a few key claims with citations. When the book lands in the hands of several Marleyan critics, they are befuddled by the lack of citation.
This experiment highlights an undesirable property of plagiarism: namely, it impedes the reader’s ability to discern the veracity of a given claim. Grounding the wrongfulness of plagiarism in this property is appealing for several reasons:
The entire existence of the academy is predicated on the notion of extending the breadth and depth of knowledge. This mission is compromised when academic texts become inscrutable due to insufficient/inaccurate citation.
The wrongfulness of plagiarism is conditioned on the interests of the scholarly community as opposed to the interests of the target (whose judgment could be emotionally compromised).
The common knowledge criterion is satisfied because ideas and facts which are already well known to the scholarly community need not be scrutinized (and thus, do not require citation).
But an astute reader may observe that this line of reasoning does not accommodate cases of plagiarism where the original source is dutifully cited but in-artfully paraphrased or copied verbatim without accompanying quotation marks.
In the above example, the reader retains the ability to trace the source of the claim being made and evaluate its veracity. Thus, more must be said about cases of plagiarism which involve copying language from sources without proper attribution.
Copyright Infringement
The copyright argument asserts that plagiarism is wrong because it violates copyright: it reproduces the expression of another individual without their consent. The underlying intuition behind the argument is that (a) scholarly works constitute intellectual property (b) intellectual property must be properly attributed when used by others.
Though the copyright argument may appear appealing on the surface, it fails to satisfy nearly all of the relevant criteria:
Copyright law does not establish a right to ideas. It only establishes a right to the expression of those ideas (U.S. Copyright Office). Thus, conceptual plagiarism is permissible under the copyright argument.
Copyright law does not establish a right to every single unit of expression contained within a creative work. Individual sentences and paragraphs may still be copied without leading to charges of copyright infringement (Bailey 2017). Thus, linguistic plagiarism is sometimes permissible under the copyright argument.
Copyright law permits the reproduction of works in the public domain without attribution (U.S. Copyright Office). Thus, both conceptual and linguistic plagiarism of these works are permissible under the copyright argument.
Copyright law does not compel an author to attribute their own work (U.S. Copyright Office).2 Thus, self-plagiarism is permissible under the copyright argument.
Thus, the copyright argument is dead on arrival.
Deception
The deception argument asserts that plagiarism is wrong because it deceives others about either the competencies of the author or the nature of the work being presented (Helgesson and Eriksson 2014). The appeal of the argument rests in its ability to satisfy each of the relevant criteria:
Conceptual plagiarism is wrong because it implies a creativity and expertise in the plagiarist which is not truly theirs.
Linguistic plagiarism is wrong because it implies a communication prowess in the plagiarist which is not truly theirs.
Self-plagiarism is wrong because it deceives others about the novelty of the contributions being made.
The common knowledge exemption is acceptable because it is impossible to deceive someone into thinking that one was the original author of common knowledge (otherwise such knowledge would not truly be common).
I suspect each of these points likely requires some additional clarification.
Creativity and Expertise
Creativity and expertise (hereby referred to as “c/e”) are integral components of the academic enterprise. Theorists must possess c/e to conceptualize compelling explanations of social and natural phenomena. Practitioners must possess c/e to design studies which subject theories to rigorous testing. And those who work under the mentorship of either theorists or practitioners must possess c/e to help carry out their vision.
This ubiquity of c/e helps illuminate the wrongfulness of conceptual plagiarism. The conceptual plagiarist does not accumulate c/e through honest effort. They merely create the perception that they are high in c/e by lying to their audiences about the origins of the ideas which they pass off as their own.3 This deception can then lead to serious problems down-the-road:
The conceptual plagiarist can be provided with power and influence (e.g. grant funding) which they are unequipped to wield effectively based on the false perception that they are high in c/e.
The conceptual plagiarist can deprive a genuinely high-c/e individual of the opportunity to wield said power and influence in a more effective manner.
We can thus see that conceptual plagiarism threatens the effectiveness of the academic enterprise by deceiving others about the plagiarist’s underlying competencies.
Communication Prowess
We can think of communication prowess as the set of communication skills which are relevant (key word: relevant) to evaluating the work of an author in a given setting (e.g. acceptance into a PhD program, journal, or tenure-track faculty position). This definition has an important implication: there are certain cases of copying language which would not be considered deception because they do not mislead others about one’s underlying communication ability.
Case #1: Boilerplate Text
These instances of copying involve text which is so mundane that they could hardly be said to constitute deception about one’s communication prowess (Helgesson and Eriksson 2014).
Case #2: Common Expressions
These instances of copying involve expressions which are so widespread that no rational person could claim that they were deceived about its origin (Helgesson and Eriksson 2014).
Case #3: Ideas Which Lack Suitable Alternative Expressions
These instances of copying involve phrases which are so uniquely expressive of a given an idea that no rational person could pass blame for having used the original phrasing (e.g. strict definitions of concepts).4
The above cases highlight that not all parts of a text are relevant to evaluating an author’s communication ability. But this raises a natural question: which parts of a text are relevant?
Feld, Lines, and Ross (2024) provide an answer to the question in the context of economics. They conduct a pre-registered experiment in which an economics paper written by a PhD student was edited by an independent writing consultant. This consultant was tasked with improving the clarity of communication contained in the title, introduction, and abstract of the paper, but not the technical methods sections. The authors then convened a panel of economists and randomly assigned either the original paper or the edited paper to be reviewed by each panelist.
The results of this experiment proved to be quite revealing:
Economists judge the overall paper quality 0.20 SD better (0.4 points on the 11-point scale) [when the paper was edited]. They are also 8.4 percentage points more likely to accept edited papers for a conference, and are 4.1 percentage points more likely to believe that edited papers will get published in an economics journal that is classified as A* or A on the ABDC journal ranking.
The paper thus lends credence to the idea that the title, abstract, and introduction of a paper are relevant to evaluating a candidate’s communication prowess - at least in economics. This conclusion is not particularly surprising given that these sections of a paper are the most public-facing and consequently, must be sufficiently comprehensible to generate impact.
An astute reader might make the following observation upon seeing this result:
If the use of a writing consultant improves the clarity of a paper, then why not let everyone use a writing consultant to submit papers to academic journals? Academics would be able to invest time into more worthwhile endeavors instead of toiling away with writer’s block all day. And academic papers would be better positioned to generate impact beyond the ivory tower due to their increased accessibility to the public. It would be a win-win situation!
I would be willing to endorse this proposal on two conditions:
The use of writing consultants must be acknowledged in the body of the paper. This acknowledgement ensures that no one is deceived about the communication prowess of the listed author.
Permitting the use of writing consultants should not lead us to abandon the expectation that scholars independently exhibit communication prowess. Many, if not most, forms of scholarly communication take place outside of the publication process (e.g. answering student questions during office hours, communicating findings to the press). We need scholars to independently exhibit communication prowess to ensure that these avenues of communication remain intact even as scholars rely on third parties to give their preprints a glow-up.5
A skeptical reader might question the necessity of the first condition. They might say:
Why should academics even be required to acknowledge the use of writing consultants to begin with? No such requirement is imposed in the legal setting. Judges routinely present arguments written by clerks as their own and lawyers copy the exact content of contracts written by others to ensure they are enforceable (Frye and Boyd 2021). Given that acknowledgement is unnecessary in the context of legal writing, why should it be necessary in the context of academic writing?
We can answer the question by noting the differences in the objectives of lawyers/judges and academics. Lawyers and judges are not evaluated on the basis of the originality of their writing. They are instead evaluated on the basis of their ability to present compelling legal arguments and maintain order under the eyes of the law, respectively (Shatz and McGrath 2013). The success of lawyers and judges is thus dependent on (as opposed to being undermined by) their ability to plagiarize.
The same cannot be said of academics. The objective of an academic is to increase the accessibility of knowledge - to pierce the veil of ignorance which currently blinds humanity to a deeper understanding of the world. This objective is undermined when academics display an insufficient level of communication prowess:
Professors who cannot clearly answer their students’ questions do not provide these students with the knowledge needed to achieve proficiency in course material.
Researchers who cannot clearly communicate novel theories, methodologies, or discoveries are limited in their ability to generate impact beyond the ivory tower.6
The upshot is that the importance placed on communication prowess is proportional to the degree to which original writing matters under the setting in question. Because original writing undeniably matters in a number of academic contexts, academics must ensure that their papers honestly reflect this skill. Doing otherwise would constitute deception.
Novelty
It is quite common to see the concept of self-plagiarism called into question even by high-profile academics.
But I would argue that this skepticism is misplaced. Journals accept publications on the condition that they represent a novel contribution to the field, and professors accept student submissions on the condition that they were not merely recycled from assignments previously submitted to other classes. The upshot is that there are many settings in academia where novelty is a strict expectation, not a polite request.
Why does this expectation of novelty matter? It matters because self-plagiarism contravenes it! The self-plagiarist, by failing to cite their own prior work, deceives their audience about the degree to which their current work represents a novel contribution. Their action thus constitutes an ethical violation for which they can reasonably be held responsible.
A skeptical reader, however, might object to this conclusion. They might say:
I think you’re using the term “deceive” in a morally-loaded way here. It is certainly wrong to intentionally pass off an assignment from a prior class as novel work for another. But is it really wrong to reuse a well-written paragraph from a paper you wrote ten years ago as part of a paper you’re working on right now? Does recycling a single paragraph really deceive others about the originality of a work?
This objection effectively presents a Ships-of-Theseus-style thought experiment: is there a certain point at which the modification of a previous work represents its own independent work?
I readily admit that I lack a definitive answer to this question because the last thing I want to do is wade into a debate about metaphysics to explain why plagiarism is wrong. But I suppose I can provide two heuristics that help indicate whether two pieces of work are sufficiently different to rebuff the charge of deception:
Is it possible to clearly articulate substantive differences (e.g. differences in methodology) between the two papers?7
Would editors be open to publishing both papers in different volumes of the same journal?
These heuristics are by no means perfect, but they can at least provide a coherent response to the objection. The act of copying a single paragraph from an old paper probably does not constitute self-plagiarism (or at least, the kind of self-plagiarism which is unethical) because the substantive differences between the original and current paper are are likely large enough to render the deception-about-novelty charge toothless. Thus, self-plagiarism is only wrong insofar as it deceives the audience about the novelty of the work in question.
(Un)common Knowledge
The deception argument posits that the common knowledge exemption is acceptable because it is impossible to deceive others into believing that one is the original author of common knowledge (otherwise such knowledge would not truly be common). But is this premise always true? The thought experiment below suggests not:
Mabel is completing an undergraduate degree in sociology with a specific interest in ethnography. One day, she encounters a paper which employs linear regression to study the relationship between household income and high school graduation. Because the paper does not accompany its use of linear regression with a citation, she assumes that the authors of the paper have created the method themselves. Months later, a fellow classmate informs her that linear regression originated well before the paper was published, leading her to feel shocked and disappointed. “I just wish they had cited that in the paper. I feel so deceived.” she says.
The issue highlighted by the thought experiment is the elusive nature of common knowledge. What does it mean to say that knowledge is “common”? And what does one do when individuals disagree as to whether a given piece of knowledge is sufficiently “common” to exempt citation?
The answer, in my view, lies in recognizing the parallels between common knowledge and its practical counterpart: common sense. The use of the descriptor “common” to describe common sense does not imply that literally everyone in the universe possesses such sense. In fact, I’m certain we’ve all met someone in our lives who’s made us question how common “common sense” truly is. Rather, the use of the “common” descriptor simply means that there is a common expectation that people possess such a sense.
The natural implication is that “common knowledge” need not be held by all individuals who read a given work. It need only be the type of knowledge which is reasonable to expect of the work’s primary intended audience. This insight allows us to resolve the conundrum posed by the thought experiment. Though Mabel may feel deceived by the authors’ failure to cite linear regression, she has not genuinely experienced deception. Her allegation of deception is completely undermined by the very reasonable expectation that readers of quantitative sociology papers be familiar with basic statistical methods.
Thus, it remains impossible to deceive others into believing that one is the original author of common knowledge because the primary intended audience of a given work is expected to be familiar with said knowledge in the first place.
Rebuttals to the Deception Argument
The previous discussion demonstrates that deception is a powerful contender to explain the wrongfulness of plagiarism. But before accepting the argument as sound, we must address two rebuttals: the competent plagiarist rebuttal and the ghostwriting rebuttal (Martin 1994).
The competent plagiarist rebuttal proceeds like so:
You claim that plagiarism is wrong because it constitutes deception about one’s underlying competencies. But this assertion seems to suggest that plagiarism is morally acceptable when it is carried out by highly competent individuals (i.e. scholars who have a well-established track record of meaningful discoveries). These scholars cannot be accused of deception about underlying competencies because they are already recognized to be highly competent on the basis of prior work.
It is quite tempting to reject the competent plagiarist rebuttal by appealing to a notion of marginal competence: namely, that each work a scholar publishes adds to the competence we ascribe to them even if they are already widely considered to be highly competent. The deception argument would then remain intact because plagiarism committed by competent individuals will still create the false impression that the plagiarist is more competent than they actually are.
I can’t help but feel, however, that this response is grasping at straws. The basic issue is that there are diminishing marginal returns to scholarly work. In particular, my perception of another scholar’s competence has little room to grow if I already consider them to be highly competent. The implication, then, is that the deception employed by a competent plagiarist ends up being pretty trivial: the difference between their actual competence and that implied by their work will not be particularly large.
The more compelling response to the competent plagiarist rebuttal is to leverage the second condition of the deception argument: namely, deception about the nature of the work being presented. The competent plagiarist violates this condition by instilling the false impression that they are the original author of the work being presented. This violation holds irrespective of whether the plagiarist is highly competent or not and thus serves as a robust shield against the rebuttal.
The ghostwriting rebuttal proceeds like so:
You claim that linguistic plagiarism is wrong because it constitutes deception about one’s underlying communication prowess. But this assertion seems to suggest that ghostwriting is immoral. We would then need to consider all of the following activities to be wrongful:
Paying a speechwriter to write speeches on behalf of a politician
Paying a ghostwriter to write a memoir on behalf of a celebrity
Paying a secretary to write emails to customers on behalf of a CEO
Paying a songwriter to write song lyrics on behalf of a singer
Note that two of these examples can be written off as irrelevant right off the bat:
The primary objective of a politician is to pass policy, not to waste time with original speechwriting. Thus, it is irrational to expect politicians to have written their speeches solely by themselves.8
The primary objective of a CEO is to provide value to shareholders, not to waste time writing emails all day. Thus, it is irrational to expect CEOs to have written their PR messaging by themselves.
The remaining two examples can be dealt with in the following manner:
Whether or not a ghostwritten celebrity memoir constitutes deception will be dependent on the expectations of the intended audience (Bailey 2015). In my view, the target audience would not use the memoir as a measure of the communication prowess harbored by the listed author. They would instead use the memoir as an opportunity to learn about the listed author’s life. The deception charge would then only be meaningful if the memoir contained false information about the listed author’s life (Bailey 2015).
The ghostwritten song lyrics do constitute deception about one’s lyricism but not about one’s general musical ability. As a case in point: Mariah Carey is the undisputed vocal powerhouse behind “All I Want For Christmas Is You” irrespective of whether or not she was the sole author of the song (Willman 2019).
The common thread through all of the above cases is that the wrongfulness of linguistic plagiarism is proportional to the degree to which original writing matters under the setting in question.
Conclusion
This essay ultimately outlines three sufficient conditions under which plagiarism is wrong:
Plagiarism is wrong when it inflicts harm to the plagiarized author.
Plagiarism is wrong when it impedes the reader’s ability to evaluate the veracity of scholarly claims.
Plagiarism is wrong when it deceives others about the underlying competencies of the author or the nature of the scholarly work in question.
We can conclude this essay by exploring how the above conditions jibe with public opinion. It turns out that people resonate greatly with the view of plagiarism as deception about underlying competencies! Silver and Shaw (2017) demonstrate that people view plagiarism as wrong because it confers “false reputational benefits” to the plagiarizer. This view remains robust even when the plagiarized target provides expressed permission to use the work without attribution and is compensated.
The deception argument thus constitutes the most robust and popular account of the wrongfulness of plagiarism.9
Addendum: Plagiarism and Property Rights
We have seen in our previous discussion of the copyright argument that many instances of plagiarism do not violate property rights in a legal sense because they do not constitute copyright infringement. But this raises an interesting question: does plagiarism violate property rights in an ethical sense?
Frye (2020) argues no:
If academic plagiarism norms give me a property right in attribution, then surely I can disclaim that right … And yet, it is unclear whether I can effectively disclaim the right of attribution created by academic plagiarism norms … In short, while the attribution right created by plagiarism norms superficially resembles an extra-legal form of copyright protection, it is actually something else entirely. Unlike copyright, the attribution right created by plagiarism norms isn’t a property right belonging to the author of a work, but an extra-legal regulatory requirement created and enforced by a discursive community [emphasis added].
This line of reasoning can be rephrased like so:
Premise #1: The implication of establishing a property right to ideas and expression is that the holder of such a right can freely exchange their property (i.e. their ideas and expression) with others in the academic marketplace.10
Premise #2: This implication clearly does not apply to plagiarism enforcement in practice. Plagiarism is still a sanctionable offense even if the originator of an idea grants expressed permission to use their work without attribution, and plagiarism guidelines can be enforced by people other than the original authors of the work in question.
Conclusion: The right to attribution cannot possibly be considered a property right in the ethical sense because it is completely inconsistent with the way that property actually functions in the real world.
I will readily admit that this line of reasoning has a powerful appeal. But it is unsound because it rests on a misunderstanding of the nature of property. To see why, we can consider the following thought experiment:
Grunkle Stan wants to bequeath several million dollars worth of assets to his great-nephew Dipper. When he looks into the paperwork to do so however, he notices that the vast majority of this money would be subject to an inheritance tax. Stan immediately dials the IRS and exclaims:
“It’s my money, so I should be able to say who it goes to after I die!”
The responding IRS agent is unamused and counters:
“Yes, the money is yours now. But why does that mean that the money should belong to Dipper after you die? What has Dipper done to deserve that money in the first place?”
Stan is stunned by the agent’s response and slams the phone on the ground in anger.
The thought experiment reveals three basic points:
It is simply untrue that property is always freely exchangeable in the manner that Frye describes. The inheritance tax clearly prevents parents from freely bequeathing the sum total of their assets to their child. Likewise, plagiarism norms prevent scholars from freely distributing their work to be used by others without attribution.
It is equally untrue that property rights may only be enforced by the holder of said rights. The inheritance tax consists of the state/public dictating how the money of the parent is distributed upon their death. Likewise, plagiarism norms consist of a “discursive community” collectively enforcing the practice of scholarly attribution.
Lastly (and most importantly), both the inheritance tax and plagiarism norms share the same underlying normative justification: namely, that people should not be allowed to receive things which they have done nothing to deserve.11
The upshot is that plagiarism certainly can be said to violate property rights in an ethical sense if one takes the ethical stance that people do not have an right to property which they have done nothing to deserve.12
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A secondary issue is that this argument is moot in cases where the plagiarized victim is dead.
O’Grady (2021) points out that publishers often hold copyright when scholars submit work to academic journals. Self-plagiarism of published work could thus constitute copyright infringement.
An analogous line of reasoning holds in the case of conceptual plagiarism committed by students. The purpose of the university is to cultivate and evaluate c/e within their students. The conceptual plagiarist violates this pedagogical aim by obfuscating the ability of the professor to properly measure the c/e they truly possess (Sadler 2007).
Though the use of a definition without citation may not constitute deception, it may run afoul of the scholarly scrutiny argument as readers would be unable to trace the definition to the original source material.
This condition can also be understood via analogy to AI-assisted coding tools (e.g. GitHub Copilot). Experienced software engineers should be encouraged to use AI to expedite the engineering process. But they must be able to debug AI-generated code and explain the end result to fellow engineers.
I do not mean to imply here that scholars with limited English proficiency ought to be barred from having their novel ideas published in English academic journals (Yilmaz 2007). My only point is that, in the event that scholars use language written by others to enhance the clarity of their work, they ought to honestly acknowledge that they did so via attribution of the source material. This acknowledgement helps signal to the reader the level of communication prowess that the author truly harbors.
Note that this heuristic does not reject replication studies. The key methodological difference between a replication study and its predecessor lies in the sample being studied.
One might object to this claim by highlighting the public outrage which ensued when Melania Trump plagiarized Michelle Obama’s 2008 DNC address. This objection is meritless, however, because (1) Trump campaign speechwriter Meredith McIver admitted it was her who unwittingly engaged in plagiarism (2) Michelle Obama’s DNC address was ghostwritten by Sarah Hurwitz (Neely 2016; Thompson 2016). The only wrong that can be said to have occurred in this case was the plagiarism of one ghostwriter’s work by another.
I want to caution against committing an ad populum fallacy here. I do not believe the deception argument is somehow more sound merely because it has popular support. I only describe popular support because it is an interesting fact about the moral intuitions held by the public.
Ghostwriting of presidential speeches and memoirs is a case in point.
It is also possible to justify both policies on consequentialist grounds:
The inheritance tax improves public welfare by redistributing income to disadvantaged populations.
Plagiarism norms improve public welfare by making it possible to easily identify genuinely competent scholars who would effectively make use of academic resources (e.g. grant funding).
I describe the desert-based account in the main body of the essay because it is a widely-held intuition in the context of plagiarism norms (Silver and Shaw 2017).
Note that this ethical stance has a clear connection to the view of plagiarism as deception. The academic prestige acquired by the plagiarist is undeserved precisely because the plagiarist has deceived the scholarly community about their competence and/or the nature of their contribution to the scholarly work in question.