Martin

Dec 23, 2024 Read Opinion

In re Marriage of May

1) Case citation and parties - In re Marriage of May, No. 1-22-1485, 2024 IL App (1st) 221485-U (1st Dist. Dec. 23, 2024). - Petitioner-Appellee: Patrick Martin May. Respondent-Appellant: Mary Lydia May. 2) Key legal issues - Whether a notice of intent to claim dissipation under the Illinois Marriage and Dissolution of Marriage Act (750 ILCS 5/503(d)(2)(ii)) must include a specific date or period when the marriage began an irretrievable breakdown, and whether omission of that timeframe is a fatal procedural defect that justifies exclusion of the dissipation claim. - Whether the opposing party waived objection to a facially defective dissipation notice by filing a substantive response. 3) Holding/outcome - The appellate court affirmed the trial court’s grant of petitioner’s motion in limine barring respondent’s dissipation claims. The court held Mary’s dissipation notices were deficient for failing to specify the date/period of irretrievable breakdown as required by section 503(d)(2)(ii), and the defect justified exclusion. Waiver argument rejected. 4) Significant legal reasoning - The court treated the statutory requirement to identify “a date or period of time during which the marriage began undergoing an irretrievable breakdown” as mandatory for a dissipation notice. That temporal allegation is necessary to define the timeframe for alleged dissipative conduct and to afford the responding spouse a fair opportunity to defend. - Mary’s separate pleadings and admissions (general allegations of irretrievable breakdown) did not cure the statutory deficiency in her dissipation notice. Nor did Patrick’s substantive denials in discovery or response amount to waiver of the procedural defect; the trial court could properly exclude the claim where the notice failed to provide the statutorily required temporal specificity and thus prejudiced the defense. - The appellate court emphasized procedural compliance with the Act’s dissipation notice rules as prerequisite to litigating dissipation at trial. 5) Practice implications (brief, for litigators) - When asserting dissipation under 750 ILCS 5/503(d)(2)(ii), plead a clear date or narrow period when the marriage began to break down — don’t rely on general petition language. - Serve amended notices promptly if the timeframe becomes clearer during discovery. - If defending against dissipation claims, object early and consider a motion in limine to exclude claims that lack the statutory timeframe, even if you substantively respond. - Preserve the record on timing (depositions, discovery responses) to avoid surprise and to rebut waiver arguments. - Treat the Act’s procedural requirements as jurisdictionally significant to avoid exclusion of claims at trial.

Oct 15, 2024 Read Opinion

In re Marriage of Jones

1. Case citation and parties - In re Marriage of Jones, 2024 IL App (2d) 240229-U (Ill. App. Ct., 2d Dist., Oct. 15, 2024). - Petitioner-Appellee: Jessica Jones. Respondent-Appellant: Martin Jones. 2. Key legal issues - Whether the trial court exceeded its authority in appointing a parenting coordinator by (a) adopting an order that altered the Rule 909 review standard, and (b) requiring parties to waive due‑process and complaint rights (e.g., to licensing/ARDC). - Whether the appellate court has jurisdiction over interlocutory challenges to the parenting‑coordinator order when some objections concern matters beyond care/custody of unemancipated minors. - Compliance of the trial court’s order with Illinois Supreme Court Rule 909 and local rules. 3. Holding/outcome - The appellate court: affirmed in part, vacated in part, dismissed in part, and remanded with directions. - The court held the trial court erred to the extent the order (1) purported to impose a different standard of review for trial-court review of parenting‑coordinator decisions and (2) ordered parties to waive due‑process/complaint rights. Otherwise, the order complied with Rule 909. - The court dismissed appellate review of issues not involving care or custody of unemancipated minors for lack of jurisdiction. 4. Significant legal reasoning - Rule 909 establishes a uniform framework for parenting coordination in Illinois, including that a trial court’s review of a parenting coordinator’s recommendations is de novo (Ill. S. Ct. R. 909(l)). A trial court cannot contractually or procedurally alter that judicial review standard in its appointment order. - Broad or blanket waivers of due‑process rights and bar(s) to filing complaints with licensing/disciplinary authorities are impermissible; parties cannot be compelled to waive fundamental procedural protections or administrative complaint avenues as a condition of participation. - The appellate court limited its review to matters within the subject‑matter jurisdiction proper to interlocutory appeals under Rule 306(a)(5)—i.e., those implicating child custody/care of unemancipated minors—and dismissed peripheral issues outside that scope. - The opinion reaffirmed that local/county parenting‑coordinator forms must conform to Rule 909’s substantive limits (e.g., scope of authority, prohibited topics, confidentiality limitations, ex parte ban, written recommendations, fee allocation). 5. Practice implications - Draft and approve parenting‑coordinator orders to track Rule 909 precisely: do not change the de novo review standard or attempt to create alternative appellate/review standards in the order. - Avoid language that purports to waive parties’ due‑process rights or to bar complaints to licensing/disciplinary bodies; preserve any concerns on the record and in written objections. - Ensure appointment orders clearly define the coordinator’s scope consistent with Rule 909(f)–(g) and local rules, and memorialize compliance with procedural protections (written recommendations, 14‑day rule, non‑confidentiality limits, no ex parte communications). - Counsel should preserve objections in writing (and request a court reporter when needed) and be mindful that interlocutory appellate review is limited to custody/care issues involving unemancipated minors.

Oct 31, 2022 Read Opinion

In re Marriage of Robin L.

- Case citation and parties In re Marriage of Robin L., 2022 IL App (4th) 220472‑U (Oct. 31, 2022) (Rule 23 order, non‑precedential). Petitioner‑Appellee: Robin L.; Respondent‑Appellant: Martin L. (Sangamon County No. 19D176). - Key legal issues 1) Whether the trial court applied a “statutorily‑lesser” or different legal standard (a changed‑circumstances standard under 750 ILCS 5/610.5(a)) at the hearing on a motion to modify parenting time, without notice, depriving respondent of due process. 2) Whether the record demonstrates reversible error in the court’s purported use of a lesser standard rather than the substantial‑change standard under 750 ILCS 5/610.5(c) (and the best‑interests inquiry). - Holding/outcome Affirmed. The Fourth District found no evidence the trial court applied any lesser legal standard; therefore, no due‑process or reversible error was shown. - Significant legal reasoning (concise) - The pleadings and prehearing positions framed the dispute around whether a “substantial change in circumstances” had occurred; Martin argued there was none and cited In re Marriage of Salvatore. The court acknowledged that argument during the hearing. - In its oral ruling the trial judge stated the governing standard as whether “there has been a change in circumstances necessary to warrant the modification” and whether modification is in the children’s best interests. The judge analyzed whether the changes were anticipated (a statutory consideration in §610.5(c)), the parties’ communication, children’s ages/schedules, and concluded the change was sufficient and that modification met best‑interest factors. - The appellate court relied on the presumption that trial courts know and apply the law correctly (In re N.B.), and noted the absence of affirmative evidence that an incorrect standard was applied. The opinion also references Trapkus (3d Dist.) as clarifying §610.5(a) does not create a separate, lower changed‑circumstances standard for parenting‑time modifications. - The court further observed appellant failed to show prejudice or preserve a reversible‑error claim (citing forfeiture rules and Saracco). - Practice implications (for attorneys) - Plead and argue the exact statutory standard you rely on (cite §610.5(c) for substantial‑change parenting‑time motions) and develop record evidence addressing that standard (anticipated changes, degree of change, best interests). - If the court appears to apply a different standard mid‑hearing, contemporaneously object, request clarification or a continuance, and put on tailored testimony. - Preserve appellate issues and include controlling authority (e.g., Trapkus) in briefs; mere assertion of an incorrect standard without showing prejudice or preserved objection is unlikely to succeed. - Remember Rule 23 orders are non‑precedential; cite relevant precedents to bolster appellate arguments.

Nov 4, 2021 Read Opinion

In re Marriage of Paris

1. Case citation and parties - In re Marriage of Paris, 2021 IL App (1st) 210828-U (1st Dist. Nov. 4, 2021) (Rule 23 order). - Petitioner-Appellee: Kerry Paris; Respondent-Appellant: Frank Martin Paris Jr. 2. Key legal issues - Whether the trial court properly granted/maintained a temporary order giving the wife exclusive possession of the marital residence under 750 ILCS 5/501(c‑2) (order allowed only where occupancy by both spouses jeopardizes the physical or mental well‑being of a spouse or children). - Whether the trial court abused its discretion in denying the husband’s motions (filed in 2021) to dissolve that injunction on grounds the original basis (home repairs/safety) no longer existed. - Jurisdictional/timeliness: whether earlier appellate challenge to the January 30, 2020 order was timely under Supreme Court Rule 307(a)(1). 3. Holding/outcome - Affirmed. The appellate court held the trial court did not abuse its discretion in denying the husband’s motions to dissolve the temporary exclusive‑possession order. - The court also concluded it lacked jurisdiction to entertain challenges to the original January 30, 2020 order because the husband’s first interlocutory appeal was untimely under Rule 307(a)(1). 4. Significant legal reasoning - Jurisdiction: Rule 307(a) requires perfection of interlocutory appeals within 30 days; the husband’s March/June 2020 attempts were untimely (earlier appeal due March 2, 2020); a motion to reconsider does not toll the Rule 307 clock. Thus, appellate review was limited to the June 9, 2021 denial of the motion to dissolve. - Substance: the trial court held an evidentiary hearing, credited testimony about how the husband’s conduct (and misuse of the prior “nesting” arrangement) endangered the wife and children, and found that rescinding exclusive possession would “lead to serious endangerment.” The repair/remediation of physical defects was not dispositive because the serious‑endangerment inquiry centers on current jeopardy (including behavioral dynamics), and credibility findings are for the trial court. Abuse‑of‑discretion review applied. 5. Practice implications (concise) - File Rule 307 interlocutory notices promptly (30 days); motions to reconsider do not toll the appeal window. - When seeking or defending exclusive possession under §501(c‑2), build the record on (a) specific jeopardy to physical/mental well‑being, (b) evidence of coercive/control dynamics, and (c) balancing of hardships to both parties and children. - Physical remediation of hazards may not alone defeat exclusive‑possession relief if the court finds risk from co‑occupancy persists; credibility and detailed factual hearings are decisive. - Preserve a full evidentiary record on changed circumstances if later moving to dissolve an injunction; address alternative housing and financial hardship in the hardship balance.

Sep 27, 2021 Read Opinion

In re Marriage of McAllister

- Case citation and parties In re Marriage of McAllister, 2021 IL App (5th) 210122‑U. Petitioner‑Appellee: Angelica Martinez McCallister; Respondent‑Appellant: Amanda Rowen McCallister. Intervenors‑Appellants: Charla and Steven Finn (Amanda’s parents). - Key legal issues 1) Whether the trial court’s modification of medical decision‑making (from Amanda’s asserted sole authority toward joint decision‑making with Angelica) was against the manifest weight of the evidence. 2) Whether the Finns (grandparents named in the parenting plan but not signatories) were entitled to intervene to defend their allotted parenting time. - Holding/outcome The Fifth District affirmed. The modification of medical decision‑making was not against the manifest weight of the evidence. The trial court did not err in denying the Finns’ petition for leave to intervene. - Significant legal reasoning (summary) • Evidence: Trial testimony and expert evaluations (notably custody evaluator Dr. Clipper and neuropsychologist Dr. Dyer) supported the trial court’s finding that joint medical decision‑making better served the children’s best interests. The evaluator recommended shared responsibility to reduce conflict, allow both parents constructive participation, and avoid repeated court involvement; Dr. Dyer did not find equal parenting time per se inappropriate. Testimony also established that Amanda had at times exercised sole authority in ways that limited Angelica’s participation. The appellate court deferred to the trial court’s credibility determinations and factual findings and concluded the record supported modification. • Intervention: The parenting plan expressly awarded “grandparents” non‑prejudicial, revocable time and the Finns were not signatories; they did not assert a separate statutory right to visitation (750 ILCS 5/602.9) or show a separate legal interest adequate to intervene. The trial court’s written denial was affirmed — the court found the plan’s plain language reflected the parties’ intent and did not err in denying intervention. - Practice implications for family law attorneys • Draft parenting plans with clear language about third‑party (grandparent) rights, including whether such rights are intended to be contractual/irrevocable or contingent and whether third parties will be signatories. • If representing third parties seeking intervention, timely assert a statutory basis (e.g., 750 ILCS 5/602.9) or demonstrate a cognizable, protectable interest beyond a contractual allocation in a parenting plan. • In disputes over medical decision‑making, develop a record on best‑interest factors and co‑parenting dynamics (use custody evaluators, treating providers, and concrete examples of exclusion or cooperation). Appellate courts will defer to trial credibility and manifest‑weight review.

Sep 23, 2021 Read Opinion

In re Marriage of Portillo

- Case citation and parties In re Marriage of Portillo, 2021 IL App (3d) 200221 (3d Dist. Sept. 23, 2021). Petitioner‑Appellee: Julie Portillo. Respondent‑Appellant: Daniel Josue Portillo Martinez. - Key legal issues 1) Whether the trial court properly admitted out‑of‑court statements by the parties’ young children in a plenary order of protection hearing (interaction of hearsay rules under the Marriage and Dissolution of Marriage Act and the Illinois Domestic Violence Act). 2) Whether the appellate court had jurisdiction to review both the plenary order of protection and a separate emergency parental‑termination order that both restricted parenting time. 3) Whether the evidence (including the children’s hearsay statements) was sufficient to support the plenary order of protection and supervised‑visitation requirements. - Holding / outcome The appellate court reversed the plenary order of protection and remanded with directions. It held it did not have jurisdiction to review the separate emergency parental‑termination order (so that order remains unchallenged). Before any rehearing, the trial court must determine whether the children’s out‑of‑court statements were sufficiently reliable and whether the children were unavailable to testify. - Significant legal reasoning (concise) The Third District focused on the admissibility prerequisites for child complainant statements offered in domestic‑relations proceedings. The court stressed that admission of such hearsay requires judicial findings demonstrating adequate safeguards of reliability (examining the time, content and circumstances of the statements) and, where the proffered statutory route requires, a showing that the child was unavailable for live testimony. The panel concluded the trial court failed to make the requisite explicit findings and instead relied on an aggregate credibility assessment and collateral allegations of prior misconduct. Because the record lacked the necessary foundational determinations as to reliability and unavailability, the evidentiary basis for the plenary protection order was inadequate. The court also applied standard jurisdictional principles to find appellant’s post‑judgment filings and notice of appeal limited review to the plenary protection order only. - Practice implications for family lawyers - When offering child hearsay in domestic relations or protection proceedings, litigants must develop and elicit record evidence on the time, content and circumstances of the statements and, if applicable, the child’s unavailability. Request and obtain explicit written or oral findings from the trial court tying admissibility to statutory and case‑law criteria. - Preserve objections and challenge improper admission of child hearsay contemporaneously and in post‑trial motions. - Be careful to separately appeal distinct orders (e.g., plenary protection vs. emergency parenting orders) if you intend review of each—failure to reference an order can limit appellate jurisdiction. - Consider calling child witnesses or establishing unavailability under the controlling statute rather than relying solely on out‑of‑court statements.

Mar 25, 2021 Read Opinion

In re Marriage of Paris

1. Case citation and parties - In re Marriage of Paris, 2021 IL App (1st) 200769‑U (1st Dist. Mar. 25, 2021). - Petitioner‑Appellee: Kerry Paris. Respondent‑Appellant: Frank Martin Paris Jr. 2. Key legal issues - Whether the trial court’s temporary award of exclusive possession of the marital residence constituted an appealable interlocutory injunction under Ill. S. Ct. R. 307(a)(1). - Whether the appellant’s notice of interlocutory appeal was timely (Rule 307(a) 30‑day requirement) and whether a motion to reconsider tolled that deadline or functioned as a motion to dissolve/modify the injunction. 3. Holding/outcome - Appeal dismissed for lack of jurisdiction. The court held the January 30, 2020 order granting temporary exclusive possession was an appealable injunctive order, but the appellant’s June 17, 2020 notice of interlocutory appeal was untimely (deadline was March 2, 2020). A post‑order motion to reconsider did not toll the Rule 307 deadline and was not equivalent to a motion to dissolve/modify the injunction. 4. Significant legal reasoning - The appellate court distinguished ministerial/administrative visitation conditions (In re Marriage of Eckersall) from injunctive orders that affect the parties’ everyday activities. Because the order excluded the husband from a residence he partly owned and granted the wife exclusive possession, it affected non‑litigation daily life and thus qualified as an injunction (citing In re Marriage of Blitstein). - Under Supreme Court Rule 307(a), interlocutory appeals of injunctions must be perfected within 30 days of the order; the 30th day falling on a weekend moved the deadline to March 2, 2020. The appellant filed on June 17, 2020. - Multiple precedents establish that a motion to reconsider in a civil case does not toll the 30‑day Rule 307 deadline and that the substance, not the label, of the motion controls. Here the motion sought reconsideration of errors in law/application, not expressly to dissolve or modify the injunction; thus it did not restart the appeal clock. 5. Practice implications - Treat temporary exclusive possession orders as appealable injunctions under Rule 307(a)(1) and calendar the 30‑day deadline precisely (account for weekends/holidays). - Do not assume a motion to reconsider tolls the Rule 307 appeal period; if intending immediate interlocutory review, file a Rule 307 notice within 30 days even while litigating post‑judgment motions, or explicitly move to dissolve/modify the injunction (and seek a timely appeal if denied). - If relief is urgent, concurrently seek a stay and prepare a prompt appellate record to preserve jurisdictional options.

Dec 19, 2019 Read Opinion

In re Marriage of Paris

- Case citation and parties In re Marriage of Paris, No. 1-18-1116, 2019 IL App (1st) 181116-U (Ill. App. Ct. Dec. 19, 2019) (Rule 23 order; non-precedential). Petitioner-Appellee: Kerry Paris (represented by Stein & Stein, Ltd.). Respondent-Appellant: Frank Martin Paris, Jr. (represented by Rosenfeld Hafron Shapiro & Farmer). - Key legal issues 1. Whether the trial court abused its discretion in finding husband had the ability to pay a $550,000 interim-fee purge. 2. Whether the court properly allocated interim fees to the husband’s own attorney and expert (i.e., whether the award to the husband’s counsel/expert was authorized). 3. Whether the contempt finding (indirect civil contempt and jail-until-purge commitment) was against the manifest weight of the evidence. - Holding / outcome The appellate court: (1) affirmed the trial court’s finding that husband had the ability to pay the $550,000 interim-fee requirement and affirmed the contempt finding and civil-contempt remedy (commitment until purge payment); (2) affirmed that husband must fund interim fees for wife’s counsel, wife’s expert, and the children’s representative; (3) reversed the portion of the interim-fee order that allocated interim fees and costs to the husband’s own attorney and expert. (Note: Rule 23 — not binding precedent except in limited circumstances.) - Significant legal reasoning (concise) - Abuse-of-discretion standard: interim-fee and sanction decisions rest with the trial court and are reviewed deferentially. The trial court may consider tax returns, financial statements, business records, lines of credit, prior payments, and expert testimony bearing on liquidity and borrowing capacity. - The court reasonably relied on evidence (tax returns showing significant income, marketable securities, expert testimony about borrowing capacity and increases in asset values, extensions of credit) to conclude husband had ability to pay despite his assertions of encumbrances and illiquidity. - Civil contempt requires willful disobedience; the record (refusal to pay as ordered, attempts to shift liability via loan documents, discovery failures) supported a finding of contumacious conduct and the coercive purge condition was permissible. - However, awarding interim fees to a party’s own counsel/expert is not statutorily authorized; the appellate court reversed that portion as outside the court’s authority. - Practice implications - Trial courts have broad but not unlimited discretion to order interim fee contributions based on realistic assessments of ability to pay (including borrowing capacity and business cashflow). Ensure a robust, admissible record on liquidity and funding alternatives. - Courts may use civil contempt and purge conditions to coerce payment, but parties should document good-faith inability to pay to defend against willfulness findings. - Do not assume a court can require an opposing party to fund that party’s own counsel or experts — such allocations may be reversed as unauthorized. Draft fee petitions to seek funding for opposing counsel/experts under statutory authority and tailor requests and evidence accordingly. - Reminder: this decision is Rule 23 (non-precedential); treat accordingly in litigation strategy.

May 23, 2012 Read Opinion

In re Marriage of McGrath

1) Case citation and parties - In re Marriage of McGrath, 2012 IL 112792 (Ill. May 24, 2012). - Mary Ellen McGrath (appellee) v. Martin Gibbons McGrath (appellant). 2) Key legal issues - Whether periodic withdrawals from an unemployed parent’s savings account constitute “income” or “net income” for calculating child support under 750 ILCS 5/505(a). - Proper statutory procedure when a trial court deviates from the child-support guidelines. 3) Holding/outcome - Illinois Supreme Court held that regular withdrawals from the account owner’s own savings are not “income” for purposes of section 505 and therefore may not be included in the statutory “net income” calculation. - The Appellate and trial court judgments were reversed and the cause remanded. The Court directed that if the trial court finds the guideline calculation cannot produce an appropriate support amount, it must state the guideline amount, explain reasons for deviation, and make an adjusted award consistent with 750 ILCS 5/505(a)(2). 4) Significant legal reasoning (concise) - Statutory framework: the Act requires calculation of a minimum guideline amount (28% for two children) based on “net income,” defined as “the total of all income from all sources” with enumerated deductions (750 ILCS 5/505(a)). - The Court relied on Rogers and ordinary dictionary meanings of “income” (a recurrent gain or benefit; money received from employment, investments, royalties, etc.). Money already owned and simply withdrawn from capital is not a recurrent gain or receipt and therefore does not fit the ordinary meaning of “income.” - The trial court correctly followed the deviation procedure (calculated guideline amount and adjusted downward) but erred in its baseline by treating withdrawals of principal as passive net income. - The decision does not resolve the separate appellate split concerning IRA or retirement-account disbursements — those issues were not before the Court. 5) Practice implications for family-law attorneys - Do not treat liquidation of a party’s capital (owner’s draws from savings/principal) as “income” when computing guideline support; distinguish capital principal from income-producing assets (interest, dividends, rent). - If arguing for a deviation from guideline support, ensure the court first calculates the guideline amount and makes explicit written findings stating the guideline number and the factual/legal basis for variance, per 505(a)(2). - Consider imputation doctrines where appropriate (voluntary unemployment, evasion, unreasonable refusal of employment), but don’t conflate asset-funded lifestyle with income absent statutory or factual basis. - Where a party receives regular distributions from investment/retirement accounts, analyze and brief whether those distributions are income (case law split on IRAs/retirements).

May 23, 2012 Read Opinion

In RE MARRIAGE OF McGRATH

1. Case citation and parties In re Marriage of McGrath, 970 N.E.2d 12 (Ill. 2012) (No. 112792; Supreme Court of Illinois, May 24, 2012). Appellee: Mary Ellen McGrath. Appellant: Martin Gibbons McGrath. 2. Key legal issues - Whether regular withdrawals from a non‑IRA savings account constitute "income" under §505 of the Illinois Marriage and Dissolution of Marriage Act for purposes of calculating child support. - Whether a court may include such withdrawals in "net income" or must instead treat the parent's asset withdrawals as a non‑income factor when deciding whether to deviate from guideline support. 3. Holding/outcome The Illinois Supreme Court reversed. Money a parent routinely withdraws from his savings account is not "income" under §505 and therefore may not be included in the calculation of net income for guideline child support. The cause was remanded for recalculation excluding those withdrawals; the trial court may still consider the parent's assets (and make a §505(a)(2) deviation finding) after computing guideline support correctly. 4. Significant legal reasoning - Statutory interpretation: §505 defines "net income" as "the total of all income from all sources" but does not define "income." Applying Rogers and ordinary dictionary definitions, the Court held "income" means recurrent gains or receipts (pay, earnings, investment returns). Withdrawals of principal from an account are not new receipts or gains because the funds already belonged to the owner. - The Court rejected the appellate court's approach of looking for an express statutory exclusion of savings withdrawals; the correct inquiry is whether the withdrawals qualify as "income" at all. - The Court emphasized proper procedure: calculate guideline support based on actual net income, then, if inappropriate, expressly deviate under §505(a)(2) and state reasons (including the noncustodial parent's financial resources under §505(a)(2)(e)). Imputation of income remains available where appropriate (e.g., voluntary unemployment), but was not applied here. 5. Practice implications (concise) - Do not rely on routine principal withdrawals from savings as "income" when arguing guideline support; oppose their inclusion on appeal under McGrath. - When a parent lives off assets, litigate two tracks: (a) compute guideline support from true net income (excluding principal withdrawals); (b) separately develop and ask the court to make an explicit §505(a)(2) deviation based on the parent's assets, withdrawals and standard of living, or seek imputation of income if evidence supports voluntary underemployment. - Trial courts must state the guideline amount and reasons for any deviation; practitioners should preserve and develop facts on asset holdings, withdrawal patterns, and employment opportunity to support deviation or imputation.