Why Doesn't J.P. Telotte Discuss Casablanca as "Film Noir"?

        Scholars use terms of art with great precision, and treat scholarly categories of evidence as if they were real things to those who produced cultural artifacts the past scholars are studying.  However, artists sometimes use techniques borrowed from a wide range of styles and eras, and they may not pay particularly close attention to "the rules" which scholars may infer later from the evidence of their behavior.  This can create scholarly blind spots in which later scholars can do profitable research.  For instance, in medieval literature, the social reality of something called "courtly love" was considered proven by its description in a single famous Latin text and frequent similar instances of literary characters' behavior, even though its wide spread practice would have meant that all medieval romantic/erotic love would have been adulterous.  Later scholars have re-examined the evidence in order to discover just what kinds of conflicted relationships existed in real medieval relationships.  Similarly, some scholars treat movies classified as "films noir" as a club to which some pictures definitely belong and others do not, according to rules they have devised, and other films they classify "cult films" according to different rules.  Question: can a "cult film" use "noir" camera technique and characterization?