"The Brief" - The ALA Blog

  • March 29, 2019 11:48 AM | Anonymous member (Administrator)

    The Illinois Supreme Court Rules Committee adopted the Appellate Lawyers Association's proposed amendment to Illinois Supreme Court Rule 274 today. The amendment clarifies that a postjudgment motion is not due until the judgment order is both final and appealable.

    Rule 274 previously stated, in relevant part, "A party may make only one postjudgment motion directed at a judgment order that is otherwise final."

    The ALA proposed the following amendment to clarify exactly when a postjudgment motion must be filed: "A party may make only one postjudgment motion directed at a judgment order that is otherwise final and appealable. The motion must be filed either within 30 days of that judgment order or within the time allowed by any extensions."

    The amendment was submitted to the Rules Committee as Proposal 17-05. After consideration, the Rules Committee adopted the proposed amendment. The new amendment takes effect on July 1, 2019.

  • March 29, 2019 11:45 AM | Anonymous member (Administrator)

    The Appellate Lawyers Association and the Sangamon County Bar Association are co-sponsoring a Roundtable Luncheon honoring the Justices of the Illinois Appellate Court, Fourth District. This event provides a unique opportunity to interact with the Justices and gain insight into the perspective of the other side of the bench.


    Date: Wednesday, April 10, 2019

    Time: Check-in for the luncheon will begin at 11:45 a.m. and lunch will be served promptly at 12:00 p.m.

    MCLE: Participants will earn one hour of MCLE credit for the luncheon. The ALA is an approved MCLE provider.

    Location: Sangamo Club, 227 E. Adams Street, Springfield, Illinois

    Cost: $25 for ALA or SCBA members; $40 for nonmembers. Lunch is included.

    PLEASE NOTE: Registrations processed on-site will be charged an additional $5 administrative fee.


    Information on how to register may be found after the jump.

    Questions? Call (630) 416-1166, ext. 303

    Register:

    1. Use our online registration system here to register for the event and also pay with a credit card. Or, if you prefer, you can register online but send a check for payment. Please note, credit card payments can only be accepted through the online registration process.

    2. Mail your completed registration form along with a check payable to ALA to:
    Chris Teed
    Appellate Lawyers Association
    1717 North Naper Boulevard, Suite 102
    Naperville, Illinois 60563


    Cancellations/Refunds: Cancellations must be received two business days prior to the event in order to receive a full refund. No refunds will be processed after this time. Cancellations must be in writing and may be submitted to cteed@wmrhq.com or faxed to (630) 596-1418. Additionally, payment is expected from no-shows.

  • March 27, 2019 11:39 AM | Anonymous member (Administrator)

    By Richard Harris
    Law Clerk to Hon. Susan F. Hutchinson, Illinois Appellate Court, Second District

    The recent passing of our dear friend and colleague, Charlie Ingrassia, has been well documented in The Brief. As former editor and co-chair, “Charlie made The Brief a go-to resource for everyone who wants to learn more about recent developments in the appellate world.” John M. Fitzgerald, A Gentleman and a Scholar: Charlie Ingrassia (1979-2019), Feb. 18, 2019. Outside of his many contributions to the Appellate Lawyers Association, Charlie is also remembered as a “gifted writer and excellent strategist.” Austin Bartlett, Remembering Charlie Ingrassia, Feb. 18, 2019. It is fitting, then, that Charlie’s keen eye for jurisdictional issues would win the day in his final case. Our sincere thanks to Lawrence S. Gosewisch, a partner at Charlie’s law firm, for sharing his memories of Charlie’s prevailing argument in Elite Storage Sols., LLC v. Ratajczak, 2019 IL App (1st) 172346-U.

    “Charlie Ingrassia worked with me at Adler Murphy & McQuillen, LLP and he and Tim Parilla handled the Elite Storage case. We successfully moved to dismiss the case against our client and Charlie and Tim handled the appeal. Charlie’s years clerking for Justice Hutchinson in the Second District Appellate Court served him well and he always looked first at jurisdictional issues. When Charlie suggested we pursue a dismissal of the appeal on jurisdictional grounds, I was at first skeptical but as usual, I deferred to my appellate specialist. Charlie pursued the argument and the appeal was dismissed. This was a particularly rewarding result for Charlie, who was battling Stage IV cancer during the entire appellate process and during most of the trial court proceedings as well. The decision came down on February 15, 2019, the same day Charlie was scheduled for yet another surgery. We immediately emailed the decision to Charlie, who acknowledged the result, gave the credit to Tim, and said he was being rolled into surgery and would study the opinion later. Charlie passed away on February 17, 2019 without ever leaving the hospital. He loved being a lawyer and he was a great one. I am so glad Charlie knew that he prevailed for our client. It was very important to him. We miss him every day.”

    Lawrence S. Gosewisch, Adler Murphy & McQuillen, LLP.

    On the merits, Elite Storage involved the denial of an insurance claim due to an alleged lapse in coverage. The plaintiff entered into a contract with Precision Builders & Contractors, LLC (Precision), to provide equipment and services for a project in Elgin. As part of the contract, Precision agreed to procure an insurance policy naming the plaintiff as an additional insured. Precision procured the policy through Maciel Ratajczak and Mr. Insurance Agency (the Ratajczak defendants). The plaintiff was later named as a defendant in a separate lawsuit relating to an injury on the work site. After learning that its claim for insurance coverage was denied based on the alleged lapse in coverage, the plaintiff filed a complaint against Precision and the Ratajczak defendants for negligence and breach of contract.

    Charlie’s law firm represented the Ratajczak defendants, who moved to dismiss the plaintiff’s second amended complaint. Notably, Precision did not join the motion. On July 12, 2017, the trial court entered an order dismissing the second amended complaint “in its entirety and with prejudice.” There was no mention, however, of the order being final and appealable under Illinois Supreme Court Rule 304(a). On August 14, 2017, the plaintiff and the Ratajczak defendants filed a “joint and routine motion for entry of a final judgment.” The parties noted that the order of dismissal did not address Precision’s status as a named defendant. They requested the entry of an agreed order clarifying that the order of dismissal was a “final and appealable final judgment.” The agreed order was entered on August 22, 2017. On September 21, 2017, the plaintiff filed a notice of appeal from the order of dismissal.

    In the appellate court, the Ratajczak defendants argued that the order of dismissal, dated July 12, 2017, was the final order in the case, thus triggering the 30-day period in which the plaintiff was required to file either its postjudgment motion or its notice of appeal. The Ratajczak defendants argued that, because the plaintiff failed to take either action within 30 days, the appeal should be dismissed for a lack of jurisdiction.

    The appellate court agreed with the Ratajczak defendants for three reasons. First, although the order of dismissal did not address Precision’s status as a named defendant, there was no need for a Rule 304(a) finding. Ordinarily, when multiple defendants are named in an action, an order dismissing one of the defendants cannot be appealed absent an express finding under Rule 304(a) that there is no just reason to delay the appeal. However, before the plaintiff filed its second amended complaint, it brought a separate action against Precision seeking relief for the same issues. As a result, the second amended complaint made no claims and sought no relief of any kind against Precision. Because the Ratajczak defendants were the only parties against whom any relief was being sought, the trial court resolved the entire matter on the merits when it granted their motion to dismiss. Moreover, by dismissing the second amended complaint “with prejudice,” the trial court indicated that the plaintiff would not be allowed to amend its complaint to bring any future claims against any of the named defendants. Therefore, the order of dismissal was a final and appealable order.

    Second, there was no revestment of jurisdiction on August 14, 2017, when the Ratajczak defendants joined the motion for entry of a final judgment. For the revestment doctrine to apply, the parties must: (1) actively participate in the proceedings; (2) fail to object to the untimeliness of the late filing; and (3) assert positions that are inconsistent with the merits of the prior judgment. Although the first two requirements were met, the third was not. The Ratajczak defendants did not assert a position that was inconsistent with the merits of the dismissal order. To the contrary, by seeking reaffirmation that the second amended complaint was dismissed in its entirety, the Ratajczak defendants merely asserted a position that was consistent with the dismissal order.

    The third reason for the appellate court’s agreement with the Ratajczak defendants was the recognized principle that appellate jurisdiction cannot be conferred by laches, consent, waiver, or estoppel. Thus, by joining the motion for the entry of a final judgment, the Ratajczak defendants neither waived their jurisdictional argument nor were they equitably estopped from contesting appellate jurisdiction. For these reasons, the appellate court held that the agreed order on August 22, 2017, was entered more than 30 days after the final order, meaning that it was void and could not be appealed.

    Although Elite Storage was filed as an unpublished order under Rule 23, its lessons should not be lost on appellate practitioners. The case teaches the importance of identifying the finality of an order that dismisses a complaint “in its entirety and with prejudice.” It also demonstrates a rare exception to the Rule 304(a) requirement in cases involving multiple defendants. It should come as no surprise to anyone who knew Charlie that he would recognize these nuances and persuade the appellate court that jurisdiction was lacking.

    Well done, Charlie.
  • March 19, 2019 12:37 PM | Anonymous member (Administrator)

    On April 18, 2019, the Appellate Lawyers Association's annual Advanced Appellate Practice Seminar will feature six presentations by judges and experienced appellate practitioners. The seminar is geared toward seasoned appellate practitioners but will be of great benefit to anyone looking to improve his or her appellate skills. Presentations include:

    • Judicial Perspectives
      • Justices Nathaniel R. Howse, Jr., and Michael B. Hyman, Illinois Appellate Court, First District
      • Justice Mary K. O'Brien, Illinois Appellate Court, Third District
      • Justice Richard P. Goldenhersh (Ret.), Illinois Appellate Court, Fifth District
    • Standards of Review
      • Hugh C. Griffin of Hall Prangel and Schoonveld LLC
    • Appellate Ethics
      • Steven F. Pflaum of Neil, Gerber & Eisenberg LLP
    • Memory Techniques for Appellate Presentations
      • Professor Patrick G. Gould of the Appalachian School of Law
    • Amicus Filings
      • Michael A. Scodro of Mayer Brown LLP
    • Electronic Filing Update
      • Tina M. Schillaci, Chief Deputy Clerk of the Illinois Appellate Court, First District

    Moderated by ALA Vice-President Gretchen Harris Sperry, Hinshaw & Culbertson LLP. Additional details, including registration information, may be found after the jump.

    Date: Thursday, April 18, 2019

    Time: 1:00 p.m. to 5:00 p.m.

    MCLE: Participants will earn 3.75 hours of MCLE credit, including 0.75 hours of professional responsibility credit. The ALA is an approved MCLE provider.

    Location: Mayer Brown LLP, 71 South Wacker Drive, Chicago, Illinois

    Cost: $35 for public-sector ALA members; $50 for private-sector ALA members; $50 for public-sector nonmembers; and $75 for private-sector nonmembers.

    PLEASE NOTE: Registrations processed on-site will be charged an additional $5 administrative fee.

    Questions? Call (630) 416-1166, ext. 303

    Register:

    1. Use our online registration system here to register for the event and also pay with a credit card. Or, if you prefer, you can register online but send a check for payment. Please note, credit card payments can only be accepted through the registration process.

    2. Mail your completed registration form along with a check payable to ALA to:

    Chris Teed
    Appellate Lawyers Association
    1717 North Naper Boulevard, Suite 102
    Naperville, IL 60563

    Cancellations/Refunds: Cancellations must be received two business days prior to the event in order to receive a full refund. No refunds will be processed after this time. Cancellations must be in writing and may be submitted to cteed@wmrhq.com or faxed to (630) 596-1418. Additionally, payment is expected from no-shows.

  • March 18, 2019 12:47 PM | Anonymous member (Administrator)

    In honor of the 200th anniversary of federal courts in Illinois, the U.S. District Court for the Northern District of Illinois and the Northern District of Illinois Court Historical Association present, "Rivers of Commerce: The Illinois Federal Courts as Umpires of Antebellum Union," a talk by Professor Alison LaCroix about the role of the Illinois federal courts in the debates over the scope of federal power in the early nineteenth century.

    When: Tuesday, April 9, 2019, 4 p.m. to 5 p.m.

    Where: U.S. District Court Northern District of Illinois, Dirksen U.S. Courthouse, Court History Museum, 21st Floor, 219 South Dearborn Street, Chicago, Illinois.

    RSVP: ilnd_rsvp@ilnd.uscourts.gov

    More details and full flyer available at: https://www.ilnd.uscourts.gov/_assets/_news/LaCroix.pdf

  • March 15, 2019 12:56 PM | Anonymous member (Administrator)

    This luncheon provides an opportunity to speak with the Justices of the Second District, the Court’s Research Director, and the Clerk of the Court in an informal setting. The Justices, Research Director, and the Clerk will discuss cases or issues of interest they have encountered during the preceding year. Numbers permitting, the ALA will seat at least one Justice or Court official at each table. Attendees may ask questions and discuss appellate practice with the Justices and thus gain the perspective of the other side of the bench.

    Date: Tuesday, April 2, 2019

    Time: 12:00 to 1:30 p.m. (check-in begins at 11:45 a.m. with lunch promptly at noon)

    MCLE: Participants will earn one hour of MCLE credit. The ALA is an approved MCLE provider.

    Location: Centre of Elgin, Heritage Ballroom, 100 Symphony Way, Elgin, Illinois.

    Cost: $40 for public-sector ALA members; $45 for private-sector ALA members; $50 for public-sector nonmembers; and $55 for private-sector nonmembers. Lunch is included.

    Registration information may be found after the jump.

    PLEASE NOTE: Registrations processed on-site will be charged an additional $5 administrative fee.

    Questions? Call (630) 416-1166, ext. 303

    Register:

    1. Use our online registration system here to register for the event and also pay with a credit card. Or, if you prefer, you can register online but send a check for payment. Please note, credit card payments can only be accepted through the online registration process.

    2. Mail your completed registration form along with a check payable to ALA to:

    Chris Teed
    Appellate Lawyers Association
    1717 North Naper Boulevard, Suite 102
    Naperville, Illinois 60563

    Cancellations/Refunds: Cancellations must be received two business days prior to the event in order to receive a full refund. No refunds will be processed after this time. Cancellations must be in writing and may be submitted to cteed@wmrhq.com or faxed to (630) 596-1418. Additionally, payment is expected from no-shows.

  • March 14, 2019 11:34 AM | Anonymous member (Administrator)

    By  Katherine A. Grosh 
    Levin Ginsburg

    This is exactly the question answered by the United States Supreme Court in Jim Yovino, Fresno County Superintendent of Schools v. Aileen Rizo, 586 U.S. ___ (2019) (Feb. 25, 2019).


    This case involved the en banc review of an April 9, 2018 decision by a three-judge panel of the United States Court of Appeals for the Ninth Circuit in an interlocutory appeal involving the Equal Pay Act, in which the Ninth Circuit reversed the district court based on a prior Ninth Circuit deci­sion involving the Equal Pay Act, Kouba v. Allstate Ins. Co., 691 F.2d 873 (1982) (“Kouba”), which the panel “believed it was compelled to follow.” 586 U.S. at ___, citing 887 F. 3d 453, 459 (2018) (en banc). The Ninth Circuit then granted en banc review “to clarify the law, including the vitality and effect of Kouba.” Id.

    Because a panel decision like Kouba can be overruled only by a decision of the en banc court or the United States Supreme Court, a purpose of the April 9, 2018 en banc decision was to announce new and binding Ninth Circuit precedent interpreting the Equal Pay Act. Judge Reinhardt, who died 11 days after the decision was issued, was the author of the Ninth Circuit opinion – but its status as a “majority opinion” of the en banc court depended on counting Judge Reinhardt’s vote; without his vote, the opinion would have been approved by only 5 of the 10 members of the panel who were still living when the decision was filed.

    The Supreme Court ruled that Judge Reinhardt was no longer a judge at the time the en banc decision in this case was filed, and therefore, the Ninth Circuit erred in counting him as a member of “the majority.” Counting his vote, the Court reasoned, effectively allowed a deceased judge to exercise the judicial power of the United States after his death. “[F]ederal judges are appointed for life, not for eternity.” Even though Judge Reinhardt fully participated in this case and authored the opinion, which (along with all concurrences) was final with voting completed by the en banc court prior to his death, the Supreme Court found that the opinion was not endorsed by a majority of the living judges at the time the opinion was “filed,” entered on the docket, and released to the public.

    In support of its decision, the Supreme Court relied on the rule it endorsed in United States v. American-Foreign S. S. Corp., 363 U. S. 685 (1960), that “a judge may change his or her position up to the very mo­ment when a decision is released,” along with 28 U. S. C. §46(c), the statutory provision authorizing the courts of appeals to hear cases en banc. In the Court’s view, Judge Reinhardt was without statutory or judicial power to participate in the en banc court’s decision at the time it was rendered. Accordingly, the Court granted the petition for certiorari, and vacated the Ninth Circuit’s judgment and remanded the case.

  • March 13, 2019 11:31 AM | Anonymous member (Administrator)

    This luncheon provides an opportunity to converse with the Justices of the First District in an informal setting. Numbers permitting, the ALA will seat at least one Justice at each luncheon table. Attendees may ask questions and discuss appellate practice with the Justices and thus gain the perspective of the other side of the bench.


    Additionally, Justice Terrence J. Lavin will provide remarks about oral arguments in the First District.


    Date: Tuesday, March 19, 2019

    Time: 12:00 to 1:30 p.m.

    MCLE: Participants will earn one hour of MCLE credit. The ALA is an approved MCLE provider.


    Location: Union League Club of Chicago, 65 West Jackson Boulevard, Chicago, Illinois. Please note the Union League Club enforces a dress code, which can be accessed here.


    Cost: $40 for public-sector ALA members; $50 for private-sector ALA members; $55 for public-sector nonmembers; and $65 for private-sector nonmembers. Lunch is included.


    Information on how to register for the event may be found after the jump.

    PLEASE NOTE: Registrations processed on-site will be charged an additional $5 administrative fee.


    Questions? Call (630) 416-1166, ext. 303

    Register:
    1. Use our online registration system here to register for the event and also pay with a credit card. Or, if you prefer, you can register online but send a check for payment. Please note, credit card payments can only be accepted through the online registration process.


    2. Mail your completed registration form along with a check payable to ALA to:


    Chris Teed
    Appellate Lawyers Association
    1717 North Naper Boulevard, Suite 102
    Naperville, Illinois 60563


    Cancellations/Refunds: Cancellations must be received two business days prior to the event in order to receive a full refund. No refunds will be processed after this time. Cancellations must be in writing and may be submitted to cteed@wmrhq.com or faxed to (630) 596-1418. Additionally, payment is expected from no-shows.

  • March 12, 2019 11:29 AM | Anonymous member (Administrator)

    On Wednesday, March 20, 2019, the Northern District of Illinois Court Historical Association, the Seventh Circuit Bar Association, and the Federal Bar Association will host, "Judicial Firsts: Trailblazers on the Federal Bench," a discussion of some of the groundbreaking jurists in the Illinois federal court system. Moderated by Judge Geraldine Soat Broan (Ret.), participants will include Judge Ilana Diamond Rovner, Chief Judge Ruben Castillo, Judge Edmond E. Chang, Judge Thomas M. Durkin, Judge Susan Pierson Sonderby (Ret.), and Judge Ann Claire Williams (Ret.).


    The event will be held at the Dirksen U.S. Courthouse, 219 South Dearborn Street, Courtroom 2525, Chicago, Illinois, from 3 p.m. to 4:30 p.m. A light reception will follow. Although the event is free, space is limited. Please RSVP to dgroboski@ag-ltd.com. 1.5 hours of Professional Responsibility (diversity/inclusion) CLE credit for Illinois, Indiana, and Wisconsin is anticipated to be available. 

  • March 06, 2019 11:27 AM | Anonymous member (Administrator)

    The Illinois Supreme Court's March Term begins on Monday, March 11, 2019. The Term will include oral argument in one criminal case and three civil cases on March 12th and 13th. Below is a listing of the cases that will be heard:

    Tuesday, March 12, 2019:   People v. Darren Johnson, No. 123318

                                                   McIntosh v. Walgreens Boots Alliance, Inc., No. 123626


    Wednesday, March 13, 2019:       Ward v. Decatur Memorial Hospital, No. 123937

                                                                Nichols v. Fahrenkamp, No. 123990

    Below is a summary of two of the cases to be argued. As always, more information about all pending criminal and civil cases is available in the ALA's Cases Pending newsletter.

    People v. Darren Johnson, No. 123318
    Defendant was charged with burglary and retail theft in connection with the allegation that he stole various items of merchandise from a Walmart with a total value less than $300. With regard to the burglary charge, he was specifically charged with knowingly entering Walmart without authority with intent to commit a theft ("burglary by unlawfully entering") rather than the other form of burglary, in which a defendant unlawfully remains within a building without authority with intent to commit a theft ("burglary by unlawfully remaining"). Under the "limited authority doctrine," authority to enter a business open to the public extends only to those who enter with a purpose consistent with the reason the building is open and not to those who enter with an intent to commit a theft inside. In People v. Bradford, 2016 IL 118674, the Court held that the limited authority doctrine does not extend to burglary by unlawfully remaining in cases in which the defendant lawfully enters during business hours and stays in designated public areas.


    Before the Illinois Supreme Court, the State asserts that the limited authority doctrine, recognized in People v. Weaver, 41 Ill. 2d 434 (1968), continues to apply to burglary by unlawfully entering, including this case. The State notes that Bradford declined to extend the doctrine to burglary by unlawfully remaining but gave no hint that the doctrine was not still good law for burglary by unlawfully entering cases. Defendant disagrees, noting that subsequent to Weaver, the retail theft statute was enacted, reflecting a legislative intent to capture shoplifting activity through that offense rather than burglary. In essence, defendant asks the Court to decline to apply the limited authority doctrine to shoplifting cases. It is undisputed that burglary generally encompasses greater penalties than retail theft, so the question boils down to whether burglary was designed to punish the greater harm posed by a person who forms the intent to steal before entering a retail store (so that burglary by unlawfully entering can still apply in this case) or the greater harm posed by a person who exceeds the authority granted in an open retail store by either entering when the store is not open to the public or by going into areas of the store in which the public is not allowed (so that burglary by unlawfully entering cannot still apply in this case).


    Ward v. Decatur Memorial Hospital, No. 123937
    This appeal addresses whether an order is final for purposes of res judicata when certain counts of a complaint are dismissed without prejudice, while other counts are simply dismissed without any indication of whether they were dismissed with or without prejudice, and the plaintiff is granted leave to replead.

    The plaintiff filed his first lawsuit against the defendant over alleged negligence in the medical treatment of his brother. The circuit court dismissed all but one count of that complaint. It specified that some of the counts were dismissed without prejudice, but did not specify whether several others were dismissed with or without prejudice. Nevertheless, the court gave the plaintiff leave to file an amended complaint. The plaintiff filed numerous amended complaints, each of which was dismissed by the trial court with leave to amend, but again unclear as to whether the counts were dismissed with or without prejudice. Eventually, the plaintiff filed a third amended complaint, which the defendant answered. Shortly before trial, the plaintiff moved for leave to file a fourth amended complaint, and the trial court denied that motion. Plaintiff then voluntarily dismissed the lawsuit. 

    The plaintiff then filed a new lawsuit based on a complaint nearly identical to his proposed fourth amended complaint in the prior lawsuit. The defendant moved to dismiss on the ground that the claims were barred by res judicata and the principle against claim splitting under Hudson v. City of Chicago, 228 Ill. 2d 462 (2008). The circuit court agreed and dismissed the refiled lawsuit.  

    The Fourth District Appellate Court reversed, holding that the various dismissals—even those that did not clearly indicate they were “without prejudice”—were not final because the circuit court had given the plaintiff leave to replead. The appellate court distinguished Hudson, which held that res judicata applies when one count of a complaint is dismissed with prejudice, the plaintiff voluntarily dismisses the remaining count, and the plaintiff files a new lawsuit asserting the voluntarily dismissed count. The appellate court noted that Hudson did not involve a dismissal with leave to replead. It also cited Foxcroft Townhome Owners Association v. Hoffman Rosner Corp., 96 Ill. 2d 150 (1983), for the proposition that when a plaintiff is given leave to file an amended complaint, it must replead counts previously dismissed with prejudice in the amended complaint, or else the dismissed claims would be deemed abandoned and not appealable. The appellate court reasoned that it would be illogical to apply res judicata when a plaintiff must replead all previously dismissed counts under Foxcroft.


    In its petition for leave to appeal, the defendant argues that the Fourth District’s decision conflicts with the First District’s decision in Kiefer v. Rust-Oleum Corp., 394 Ill. App. 3d 485 (1st Dist. 2009), and Hudson. The defendant claims that the appellate court’s decision will encourage claim splitting, which is what res judicata is designed to avoid. In his answer to the petition for leave to appeal, plaintiff contends that the Fourth District correctly interpreted Hudson and Foxcroft.

DISCLAIMER: The Appellate Lawyers Association does not provide legal services or legal advice. Discussions of legal principles and authority, including, but not limited to, constitutional provisions, statutes, legislative enactments, court rules, case law, and common-law doctrines are for informational purposes only and do not constitute legal advice.

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