clear and unequivocal rule in Tennessee

2026In conducting plain error review, our court will reverse for plain error only if the five following prerequisites are satisfied: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is ‘necessary to do substantial justice.’ State v. Smith, 24 S.W.3d 274, 282 (Tenn. 2000) (quoting State v. Adkisson, 899 S.W.2d 626, 641-42 (Tenn. Crim.

2026For this court to find plain error, “(a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is ‘necessary to do substantial justice.’” State v. Smith, 24 S.W.3d 274, 282 (Tenn. 2000) (quoting State v. Adkisson, 899 S.W.2d 626, 641-42 (Tenn. Crim.

2026In conducting plain error review, our court will reverse for plain error only if the five following prerequisites are satisfied: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is ‘necessary to do substantial justice.’ State v. Smith, 24 S.W.3d 274, 282 (Tenn. 2000) (quoting State v. Adkisson, 899 S.W.2d 626, 641-42 (Tenn. Crim.

2026When considering a claim under the plain error doctrine, this court considers whether: (1) the record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the issue was not waived for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. - 26 - State v. Linville, 647 S.W.3d 344 , 353-54 (Tenn. 2022) (citation omitted); see also State v. Smith, 24 S.W.3d 274, 282 (Tenn. 2000).

2026The doctrine of plain error applies when all five of the following factors have been established: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused must not have waived the issue for tactical reasons; and (e) consideration of the error must be "necessary to do substantial justice." State v. Page, 184 S.W.3d 223, 230-31 (Tenn. 2006) (quoting State v. Terry, 118 S.W.3d 355,360 (Tenn. 2003)) (internal brackets omitted).

2025The doctrine of plain error applies when all five of the following factors have been established: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused must not have waived the issue for tactical reasons; and (e) consideration of the error must be “necessary to do substantial justice.” State v. Page, 184 S.W.3d 223, 230-31 (Tenn. 2006) (quoting State v. Terry, 118 S.W.3d 355, 360 (Tenn. 2003)) (internal brackets omitted).

2026The doctrine of plain error applies when all five of the following factors have been established: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused must not have waived the issue for tactical reasons; and (e) consideration of the error must be "necessary to do substantial justice." State v. Page, 184 S.W.3d 223, 230-31 (Tenn. 2006) (quoting State v. Terry, 118 S.W.3d 355,360 (Tenn. 2003)) (internal brackets omitted).

2025The doctrine of plain error applies when all five of the following factors have been established: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused must not have waived the issue for tactical reasons; and (e) consideration of the error must be “necessary to do substantial justice.” State v. Page, 184 S.W.3d 223, 230-31 (Tenn. 2006) (quoting State v. Terry, 118 S.W.3d 355, 360 (Tenn. 2003)) (internal brackets omitted).

2026To establish plain error, a defendant has the burden of establishing the following factors: (a) the record clearly establishes what occurred in the trial court; (b) a clear and unequivocal rule of law has been breached; (c) a substantial right of the accused has been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is “necessary to do substantial justice.” State v. Martin, 505 S.W.3d 492, 504 (Tenn. 2016).

2024Plain error relief is appropriate when: (a) the record clearly establishes what occurred in the trial court; (b) a clear and unequivocal rule of law has been breached; (c) a substantial right of the accused has been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is “necessary to do substantial justice.” State v. Martin, 505 S.W.3d 492, 504 (Tenn. 2016) (citations omitted); see also Tenn. R.

2024This court will grant relief for plain error only when: (1) the record clearly establishes what occurred in the trial court; (2) the error breached a clear and unequivocal rule of law; (3) the error adversely affected a substantial right of the complaining party; (4) the error was not waived for tactical purposes; and (5) substantial justice is at stake; that is, the error was so significant that it “probably changed the outcome of the trial.” State v. Hatcher, 310 S.W.3d 788, 808 (Tenn. 2010) (quoting State v. Smith, 24 S.W.3d 274, 282-83 (Tenn. 2000)).

2023This court will grant relief for plain error only when: (1) the record clearly establishes what occurred in the trial court; (2) the error breached a clear and unequivocal rule of law; (3) the error adversely affected a substantial right of the complaining party; (4) the error was not waived for tactical purposes; and (5) substantial justice is at stake; that is, the error was so significant that it “probably changed the outcome of the trial.” State v. Hatcher, 310 S.W.3d 788, 808 (Tenn. 2010) (quoting State v. Smith, 24 S.W.3d 274, 282-83 (Tenn. 2000)).

2025An appellate court may review an unpreserved error pursuant to the plain error doctrine, if the defendant bears his or her burden to show that all five prerequisites are satisfied: (1) The record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. -6- State v. Dotson, 450 S.W.3d 1, 49 (Tenn. 2014) (quoting State v. Gomez, 239 S.W.3d 733, 737

2024However, an appellate court may review an unpreserved error pursuant to the plain error doctrine, if the defendant bears their burden to show that all five prerequisites are satisfied: (1) The record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. - 19 - State v. Dotson, 450 S.W.3d 1, 49 (Tenn. 2014) (quoting State v. Gomez, 239 S.W.3d 73

2026State v. Minor, 546 S.W.3d 59, 74 (Tenn. 2018); see State v. Enix, 653 S.W.3d 692 , 701 (Tenn. 2022) (“To obtain relief under plain error review, the defendant bears the burden of persuading the appellate court that . . . (1) the record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice.” (citation omitted)).

2022Five factors are relevant when deciding whether an error constitutes “plain error” in the absence of an objection at trial: “(a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is ‘necessary to do substantial justice.’” State v. Smith, 24 S.W.3d 274, 282 (Tenn. 2000) (quoting Adkisson, 899 S.W.2d at 641 - 42); see also State v. Minor, 546 S.W

2026To obtain relief under this doctrine, the defendant bears the burden of persuading this Court “that the trial court committed plain error” and that the error was of sufficient magnitude “that it probably changed the outcome of the trial.” Bledsoe, 226 S.W.3d at 354 (Tenn. 2007) (first quoting State v. Adkisson, 899 S.W.2d 626, 642 (Tenn. Crim.

2015“It is the accused‟s burden to persuade an appellate court that the trial court committed plain error.” State v. Bledsoe, 226 S.W.3d 349, 355 (Tenn. 2007) (citing United States v. Olano, 507 U.S. 725, 734 (1993)). “[T]he presence of all five factors must be established by the record before this Court will recognize the existence of plain error, and complete consideration of all the factors is not necessary when it is clear from the record that at least one of the factors cannot be established.” Smith, 24 S.W.3d at 283 . - 16 - Here, the record fails to establish the breach of a clear and unequ

2020For an error to constitute plain error sufficient to merit relief, the following factors must be present: (1) the record must clearly establish what occurred in the trial court; (2) a clear and unequivocal rule of law must have been breached; (3) a substantial right of the accused must have been adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice -9- State v. Bishop, 431 S.W.3d 22, 44 (Tenn. 2014) (citing State v. Adkisson, 899 S.W.2d 626, 641-42 (Tenn. Crim.

2019For an error to constitute plain error, the following factors must be present: (1) the record must clearly establish what occurred in the trial court; (2) a clear and unequivocal rule of law must have been breached; (3) a substantial right of the accused must have been adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. - 18 - State v. Bishop, 431 S.W.3d 22, 44 (Tenn. 2014) (citing State v. Adkisson, 899 S.W.2d 626, 641-42 (Tenn. Crim.

2017In Tennessee, an appellate court will grant relief for plain error only if (a) the record clearly establishes what occurred in the trial court; (b) a clear and unequivocal rule of law has been breached; (c) a substantial right of the accused has been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is “necessary to do substantial justice.” Id. (citing State v. Michael Smith, 492 S.W.3d 224, 232-33 (Tenn. 2016); State v. Donald Smith, 24 S.W.3d 274, 282 (Tenn. 2000)). “‘[T]he presence of all five factors must be established by

2013This Court has the discretionary authority to grant relief for plain error when all of the following five prerequisites are satisfied: “(1) the record clearly establishes what occurred in the trial court, (2) a clear and unequivocal rule of law was breached, (3) a substantial right of the accused was adversely affected, (4) the accused did not waive the issue for tactical reasons, and (5) consideration of the error is necessary to do substantial justice.” State v. Hester, 324 S.W.3d 1, 56 (Tenn. 2010) (citing State v. Gomez, 239 S.W.3d 733, 737 (Tenn. 2007)).

2022To be entitled to relief under the doctrine of plain error, a defendant has the burden to establish the presence of the following five factors: (1) the record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the issue was not waived for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. - 20 - State v. Vance, 596 S.W.3d 229 , 254 (Tenn. 2020) (citations omitted). “‘Moreover, the error must have been of ‘sufficient magnitude that

2017In Tennessee, an appellate court will grant relief for plain error only if (a) the record clearly establishes what occurred in the trial court; (b) a clear and unequivocal rule of law has been breached; (c) a substantial right of the accused has been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is “necessary to do substantial justice.” Id. (citing State v. Michael Smith, 492 S.W.3d 224, 232-33 (Tenn. 2016); State v. Donald Smith, 24 S.W.3d 274, 282 (Tenn. 2000)). “‘[T]he presence of all five factors must be established by

2018This court will grant relief for plain error pursuant to Rule 36(b) only when: “(1) the record clearly establishes what occurred in the trial court; (2) the error breached a clear and unequivocal rule of law; (3) the error adversely affected a substantial right of the complaining party; (4) the error was not waived for tactical purposes; and (5) substantial justice is at stake.” State v. Cooper, 321 S.W.3d 501, 506 (Tenn. 2010) (quoting State v. Hatcher, 310 S.W.3d 788, 808 (Tenn. 2010)).

2018This court will grant relief for plain error pursuant to Rule 36(b) only when: “(1) the record clearly establishes what occurred in the trial court; (2) the error breached a clear and unequivocal rule of law; (3) the error adversely affected a substantial right of the complaining party; (4) the error was not waived for tactical purposes; and (5) substantial justice is at stake.” State v. Cooper, 321 S.W.3d 501, 506 (Tenn. 2010) (quoting State v. Hatcher, 310 S.W.3d 788, 808 (Tenn. 2010)).

2025An appellate court may review an unpreserved error pursuant to the plain error doctrine, if the defendant bears his or her burden to show that all five prerequisites are satisfied: (1) The record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. -6- State v. Dotson, 450 S.W.3d 1, 49 (Tenn. 2014) (quoting State v. Gomez, 239 S.W.3d 733, 737

2024However, an appellate court may review an unpreserved error pursuant to the plain error doctrine, if the defendant bears their burden to show that all five prerequisites are satisfied: (1) The record clearly establishes what occurred in the trial court; (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected; (4) the accused did not waive the issue for tactical reasons; and (5) consideration of the error is necessary to do substantial justice. - 19 - State v. Dotson, 450 S.W.3d 1, 49 (Tenn. 2014) (quoting State v. Gomez, 239 S.W.3d 73

2018“It is the accused’s burden to persuade an appellate court that the trial court -25- committed plain error.” State v. Bledsoe, 226 S.W.3d 349, 355 (Tenn. 2007) (citing United States v. Olano, 507 U.S. 725, 734 (1993)). “[T]he presence of all five factors must be established by the record before this [c]ourt will recognize the existence of plain error, and complete consideration of all the factors is not necessary when it is clear from the record that at least one of the factors cannot be established.” Smith, 24 S.W.3d at 283 .

2015“It is the accused‟s burden to persuade an appellate court that the trial court committed plain error.” State v. Bledsoe, 226 S.W.3d 349, 355 (Tenn. 2007) (citing United States v. Olano, 507 U.S. 725, 734 (1993)). “[T]he presence of all five factors must be established by the record before this Court will recognize the existence of plain error, and complete consideration of all the factors is not necessary when it is clear from the record that at least one of the factors cannot be established.” Smith, 24 S.W.3d at 283 . - 16 - Here, the record fails to establish the breach of a clear and unequ

2025In Tennessee, an appellate court will grant relief for plain error only if (a) the record clearly establishes what occurred in the trial court; (b) a clear and unequivocal rule of law has been breached; (c) a substantial right of the accused has been adversely affected; (d) the accused did not waive the issue for tactical reasons; and (e) consideration of the error is “necessary to do substantial justice.” State v. Smith, 492 S.W.3d 224, 232-33 (Tenn. 2016); State v. Smith, 24 S.W.3d 274, 282 (Tenn. 2000) (citing State v. Adkisson, 899 S.W.2d 626, 642 (Tenn. Crim.

2017State v. Smith, 492 S.W.3d 224, 232 (Tenn. 2016) (stating that failure to raise an election of offenses issue in the trial court waives direct appellate review but does not preclude plain error review). -7- The doctrine of plain error applies when all five of the following factors have been established: (a) the record must clearly establish what occurred in the trial court; (b) a clear and unequivocal rule of law must have been breached; (c) a substantial right of the accused must have been adversely affected; (d) the accused must not have waived the issue for tactical reasons; and (e) conside

2022Furthermore, the “plain error must be of such a great magnitude that it probably changed the outcome of the trial.” Adkisson, 899 S.W.2d at 642 (internal quotation marks omitted) (quoting United States v. Kerley, 838 F.2d 932, 937 (7th Cir. 1988)).

2022Furthermore, the “‘plain error must be of such a great magnitude that it probably changed the outcome of the trial.’” Adkisson, 899 S.W.2d at 642 (quoting United States v. Kerley, 838 F.2d 932, 937 (7th Cir. 1988)).

2012See State v. Cribbs, 967 S.W.2d 773, 783 (Tenn. 1998); State v. Cone, 665 S.W.2d 87, 94 (Tenn. 1984).

2010See State v. Cribbs, 967 S.W.2d 773, 783 (Tenn. 1998); State v. Cone, 665 S .W.2d 87, 94 (Tenn. 1984).

2012This Court has the discretionary authority to grant relief for plain error when all of the following five prerequisites are satisfied: “‘(1) the record clearly establishes what occurred in the trial court, (2) a clear and unequivocal rule of law was breached, (3) a substantial right of the accused was adversely affected, (4) the accused did not waive the issue for tactical reasons, and (5) consideration of the error is necessary to do substantial justice.’” State v. Jordan, 325 S.W.3d 1, 58 (Tenn. 2010) (quoting State v. Banks, 271 S.W.3d 90, 119-20 (Tenn. 2008)).

2012This Court has the discretionary authority to grant relief for plain error when the following five prerequisites are satisfied: “(1) the record clearly establishes what occurred in the trial court, (2) a clear and unequivocal rule of law was breached; (3) a substantial right of the accused was adversely affected, (4) the accused did not waive the issue for tactical reasons, and (5) consideration of the error is necessary to do substantial justice.” State v. Jordan, 325 S.W.3d 1, 58 (Tenn. 2010) (quoting State v. Banks, 271 S.W.3d 90 , 119- 20 (Tenn. 2008)).

2025See id.; see also State v. Fusco, 404 S.W.3d 504, 535 (Tenn. Crim.

2025See, e.g., State v. Walls, 537 S.W.3d 892, 904 (Tenn. 2017) (declining to grant relief under plain error review of late night court proceedings due to “a lack of a clear and unequivocal rule of law” on the issue); Dotson, 450 S.W.3d at 72 (concluding that “no clear rule of law” was breached by the admission of autopsy reports prepared by a non-testifying expert and the testimony of another medical examiner regarding the reports “[g]iven the uncertainty that has existed in Confrontation Clause jurisprudence since Crawford, and in particular the lack of clarity regarding expert reports and testi

2012See State v. Cribbs, 967 S.W.2d 773, 783 (Tenn. 1998); State v. Cone, 665 S.W.2d 87, 94 (Tenn. 1984).

2010See State v. Cribbs, 967 S.W.2d 773, 783 (Tenn. 1998); State v. Cone, 665 S.W.2d 87, 94 (Tenn. 1984).

2025See, e.g., State v. Walls, 537 S.W.3d 892, 904 (Tenn. 2017) (declining to grant relief under plain error review of late night court proceedings due to “a lack of a clear and unequivocal rule of law” on the issue); Dotson, 450 S.W.3d at 72 (concluding that “no clear rule of law” was breached by the admission of autopsy reports prepared by a non-testifying expert and the testimony of another medical examiner regarding the reports “[g]iven the uncertainty that has existed in Confrontation Clause jurisprudence since Crawford, and in particular the lack of clarity regarding expert reports and testi

2024State v. Walls, 537 S.W.3d 892, 901 (quoting State v. Martin, 505 S.W.3d 492, 504 (Tenn. 2016)). - 22 - Petitioner has not demonstrated that a clear and unequivocal rule of law was breached or that a substantial right was affected by Juror 2’s presence on the jury.

2017The State first argues that the Defendant cannot show that a clear and unequivocal rule of law was breached by the omission of the instruction because at the time of his March 2016 trial, it was unclear whether part (b) of the State v. Burns, 6 S.W.3d 453 (Tenn. 1999), test for lesser-included offenses survived the enactment of Tennessee Code -12- Annotated section 40-18-110(f) and (g), which codified a lesser-included offense test that included parts (a) and (c), but omitted part (b) of the Burns test.

2012We begin our determination of whether a clear and unequivocal rule of law has been breached by reviewing the standard established in State v. Burns, 6 S.W.3d 453 (Tenn.1999), for determining what constitutes a lesser-included offense: An offense is a lesser-included offense if: (a) all of its statutory elements are included within the statutory elements of the offense charged; or (b) it fails to meet the definition in part (a) only in the respect that it contains a statutory element or elements establishing (1) a different mental state indicating a lesser kind of culpability; and/or (2) a less

2026See Tenn. Code Ann. § 40-18-110 (b) (“In the absence of a written request from a party specifically identifying the particular lesser included offense or offenses on which a jury instruction is sought, the trial judge may charge the jury on any lesser included offense or offenses, but no party shall be entitled to any lesser included offense charge.”); State v. Fayne, 451 S.W.3d 362, 371 (Tenn. 2014) (stating that failure to request a lesser included offense instruction in writing does not prohibit “consideration of the issue under the doctrine of plain error”); see also State v. Linville, 647

2018See id. at 372 (citing State v. Terry, 118 S.W.3d 355, 360 (Tenn. 2003) (holding, in the context of plain error review, “[w]hile a defendant is entitled to a correct and complete charge of the law, this Court has previously held that the omission of an instruction on a lesser[-]included offense does not result in the breach of a clear and unequivocal rule of law when the status of the crime as a lesser[-]included - 14 - offense is not apparent based on prior law.”)).

2022See Smith, 24 S.W.3d at 282 ; Adkisson, 899 S.W.2d at 641-42 ; see also White, 362 S.W.3d at 562 .

2014See State v. White, 362 S.W.3d 559 (Tenn. 2012) (overruling State v. Richardson, 251 S.W.3d 438 (Tenn. 2008); State v. Fuller, 172 S.W.3d 533 (Tenn. 2005); State v. Cozart, 54 S.W.3d 242 (Tenn. 2001); State v. Dixon, 957 S.W.2d 532 (Tenn. 1997); State v. Anthony, 817 S.W.2d 299 (Tenn. 1991)).

2025App. P. 36(b) (“When necessary to do substantial justice, an appellate court may consider an error that has affected the substantial rights of a party at any time, even though the error was not raised in the motion for a new trial or assigned as error on appeal.”); see also State v. Knowles, 470 S.W.3d 416, 424 (Tenn. 2015) (“Because the election requirement safeguards a criminal defendant’s fundamental, constitutional right to a unanimous jury verdict, errors pertaining to the sufficiency of the prosecution’s election are subject to plain error review.”) Under plain error review, relief will

2021That being said, the State should have made this clear at the close of its case-in-chief, and its failure to do so arguably “breached a clear and unequivocal rule of law.” Knowles, 470 S.W.3d at 425 .

2018In Schiefelbein, this court concluded that the trial court’s question to an expert witness did not breach a clear and unequivocal rule of law or affect a substantial right of the defendant because there was no “indication of the trial court’s opinion of the evidence, and the jury was properly informed that it had complete fact-finding authority.” Id. at 120 .

2009Regarding the question of whether a clear and unequivocal rule of law has been breached, we note that our courts have long held that “the propriety, scope, manner, and control of cross-examination rests within the sound discretion of the trial court.” State v. Schiefelbein, 230 S.W.3d 88, 133 (Tenn. Crim.

2025The State’s final closing argument was within the bounds of the “great latitude” given to parties’ in arguing their cases to the jury, see Smith v. State, 527 S.W.2d 737, 739 (Tenn. 1975), and not a breach of a clear and unequivocal rule of law.

2013Initially, we note that “argument of counsel is a valuable privilege that should not be unduly restricted.” Smith v. State, 527 S.W.2d 737, 739 (Tenn. 1975).

2024See id.; see also State v. Bowman, 327 S.W.3d 69, 94 (Tenn. Crim.

2024See id.; see also State v. Bowman, 327 S.W.3d 69, 94 (Tenn. Crim.

2020A defendant in a criminal case “has a right to a correct and complete charge of the law, so that each issue of fact raised by the evidence will be submitted to the jury on proper instructions.” State v. Garrison, 40 S.W.3d 426, 432 (Tenn. 2000); see State v. Leath, 461 S.W.3d 73, 105 (Tenn. Crim.

2017See State v. Fayne, 451 S.W.3d 362, 372 (Tenn. 2014). -22- Hanson, 279 S.W.3d at 280 (citing State v. Garrison, 40 S.W.3d 426, 432 (Tenn. 2000)).