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In the case type listing, the various actions available are determined by combinations of is_active and is_reserved. However in javascript:

var x = "0";
if (x) {console.log('true'); } else {console.log('false');}
x = "1";
if (x) {console.log('true'); } else {console.log('false');}

will output true for both. Similarly for !x it will output false for both.

This comes up a couple ways:

1. The stock case types can't be deleted. (It's probably always been assumed this was on purpose for a reason, that they are "special". I can't think why this would be true - there's nothing in core that references them except they get loaded automatically when you first enable civicase.)
2. And to disable the stock types there's no dropdown option you have to go in and edit the "enabled" field.
3. After you disable a case type (stock or not), the dropdown action still says "Disable".

I'm thinking it's always been like this.