rational basis test (West Virginia) · Go Syfert
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rational basis test in West Virginia

20 West Virginia opinions name it 2 courts 1977–2025 5 in the last five years

The cases below were cited by West Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
City of Cleburne v. Cleburne Living Center, Inc.green
scotus · 1985 · cited in 4 West Virginia opinions naming this issue, 1985–2022
2 sentences

2022Petitioner does not explicitly state which constitutional provision or provisions West Virginia Code § 15-12-2(e)(1) violates, although petitioner does assert, “Under the Fourteenth Amendment to the United States Constitution and Section 10, Article III, of the West Virginia Constitution this Court has applied the ‘rational basis’ test when analyzing statutes under due process challenges.” Petitioner further asserts that “under the rational basis test, a law will be upheld so long as it is rationally related to a legitimate state interest.” In support of this position, he cites to the followin

2022Petitioner does not explicitly state which constitutional provision or provisions West Virginia Code § 15-12-2(e)(1) violates, although petitioner does assert, “Under the Fourteenth Amendment to the United States Constitution and Section 10, Article III, of the West Virginia Constitution this Court has applied the ‘rational basis’ test when analyzing statutes under due process challenges.” Petitioner further asserts that “under the rational basis test, a law will be upheld so long as it is rationally related to a legitimate state interest.” In support of this position, he cites to the followin

24
Payne v. Huntington Union Free School Districtgreen
nyed · 2002 · cited in 2 West Virginia opinions naming this issue, 2022–2025
2 sentences

2025Dist., 219 F. Supp.2d 273, 284 (E.D.N.Y. 2002).

2022Dist., 219 F. Supp.2d 273, 284 (E.D.N.Y. 2004).

22
Western & Southern Life Ins. Co. v. State Bd. of Equalization of Cal.green
scotus · 1981 · cited in 2 West Virginia opinions naming this issue, 2022–2025
2 sentences

2025Co. v. State Bd. of Equalization, 451 U.S. 648, 674 (1981)).

2022Co. v. State Bd. of Equalization, 451 U.S. 648, 674 (1981) (quoting United States v. Carolene Prods.

22
Massachusetts Board of Retirement v. Murgiagreen
scotus · 1976 · cited in 2 West Virginia opinions naming this issue, 1991–1992
2 sentences

1992In Gibson v. West Virginia Department of Highways, 185 W.Va. at 220, 406 S.E.2d at 446 , we recognized that under the rational basis test, the classification process is peculiarly a legislative function: “The Supreme Court expressed this point in Schweiker v. Wilson, 450 U.S. 221, 234 , 101 S.Ct. 1074, 1083 , 67 L.Ed.2d 186, 198 (1981), quoting Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 314 , 96 S.Ct. 2562, 2567 , 49 L.Ed.2d 520, 525 (1976): *603 ‘ “This inquiry employs a relatively relaxed standard reflecting the Court’s awareness that the drawing of lines that create distinct

1992In Gibson v. West Virginia Department of Highways, 185 W.Va. at 220, 406 S.E.2d at 446 , we recognized that under the rational basis test, the classification process is peculiarly a legislative function: “The Supreme Court expressed this point in Schweiker v. Wilson, 450 U.S. 221, 234 , 101 S.Ct. 1074, 1083 , 67 L.Ed.2d 186, 198 (1981), quoting Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 314 , 96 S.Ct. 2562, 2567 , 49 L.Ed.2d 520, 525 (1976): *603 ‘ “This inquiry employs a relatively relaxed standard reflecting the Court’s awareness that the drawing of lines that create distinct

22
Schweiker v. Wilsongreen
scotus · 1981 · cited in 2 West Virginia opinions naming this issue, 1991–1992
2 sentences

1992In Gibson v. West Virginia Department of Highways, 185 W.Va. at 220, 406 S.E.2d at 446 , we recognized that under the rational basis test, the classification process is peculiarly a legislative function: “The Supreme Court expressed this point in Schweiker v. Wilson, 450 U.S. 221, 234 , 101 S.Ct. 1074, 1083 , 67 L.Ed.2d 186, 198 (1981), quoting Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 314 , 96 S.Ct. 2562, 2567 , 49 L.Ed.2d 520, 525 (1976): *603 ‘ “This inquiry employs a relatively relaxed standard reflecting the Court’s awareness that the drawing of lines that create distinct

1992In Gibson v. West Virginia Department of Highways, 185 W.Va. at 220, 406 S.E.2d at 446 , we recognized that under the rational basis test, the classification process is peculiarly a legislative function: “The Supreme Court expressed this point in Schweiker v. Wilson, 450 U.S. 221, 234 , 101 S.Ct. 1074, 1083 , 67 L.Ed.2d 186, 198 (1981), quoting Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 314 , 96 S.Ct. 2562, 2567 , 49 L.Ed.2d 520, 525 (1976): *603 ‘ “This inquiry employs a relatively relaxed standard reflecting the Court’s awareness that the drawing of lines that create distinct

22
Teigen v. Renfrowgreen
ca10 · 2007 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025In SSAC, the court declared that courts “must independently consider whether there is any conceivable rational basis for the classification, regardless of whether the reason ultimately relied on is provided by the parties or the court.” Id. at 334 n.6, 880 S.E.2d at 56 n.6 (citing Teigen v. Renfrow, 511 F.3d 1072, 1084 (10th Cir. 2007); and Starlight Sugar, Inc. v. Soto, 253 F.3d 137, 146 (1st Cir. 2001) (recognizing that even if the government's stated justification for enforcing a regulation is insufficient to uphold the rationality of the regulation, a court has the obligation to seek out o

11
Starlight Sugar, Inc. v. Sotogreen
ca1 · 2001 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025In SSAC, the court declared that courts “must independently consider whether there is any conceivable rational basis for the classification, regardless of whether the reason ultimately relied on is provided by the parties or the court.” Id. at 334 n.6, 880 S.E.2d at 56 n.6 (citing Teigen v. Renfrow, 511 F.3d 1072, 1084 (10th Cir. 2007); and Starlight Sugar, Inc. v. Soto, 253 F.3d 137, 146 (1st Cir. 2001) (recognizing that even if the government's stated justification for enforcing a regulation is insufficient to uphold the rationality of the regulation, a court has the obligation to seek out o

11
Raley v. Wagnergreen
ark · 2001 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025Ctr., 483 P.3d 365 , 377 (Idaho 2021) (under the rational basis test, a statute of limitations that created different time limits for subclassifications of minors to bring medical malpractice claims was rationally related to the governmental purpose to reduce the risk faced by insurance companies and the cost of medical malpractice insurance); Raley v. Wagner, 57 S.W.3d 683, 688 (Ark. 2001) (a shorter two-year statute of limitations that applied to minors with medical malpractice claims as opposed to minors with other tort claims subject to a general savings statute did not violate equal prote

11
Smith v. Cobb County-Kennestone Hospital Authoritygreen
ga · 1992 · cited in 1 West Virginia opinions naming this issue, 2025–2025
1 sentence

2025Auth., 423 S.E.2d 235, 239 (Ga. 1992) (a statute that treated medical malpractice claims of minors differently than other tort claims was constitutional under the rational basis test). 14 his burden of establishing that West Virginia Code § 55-7B-4(c) lacks a rational basis.

11
Murray Energy v. Dale Steager, State Tax Comm'rgreen
wva · 2019 · cited in 1 West Virginia opinions naming this issue, 2025–2025
2 sentences

2025Va. 629, 644 , 827 S.E.2d 417, 432 (2019) stating that “the Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification.” Finally, the language used in the SSAC case makes clear that the highly deferential standard adopted by the United States Supreme Court should be utilized when 4 a court in West Virginia applies the rational basis test.

2025In SSAC, the court declared that courts “must independently consider whether there is any conceivable rational basis for the classification, regardless of whether the reason ultimately relied on is provided by the parties or the court.” Id. at 334 n.6, 880 S.E.2d at 56 n.6 (citing Teigen v. Renfrow, 511 F.3d 1072, 1084 (10th Cir. 2007); and Starlight Sugar, Inc. v. Soto, 253 F.3d 137, 146 (1st Cir. 2001) (recognizing that even if the government's stated justification for enforcing a regulation is insufficient to uphold the rationality of the regulation, a court has the obligation to seek out o

11
James E. Zombro v. Baltimore City Police Department Bishop L. Robinson, Commissioner, Baltimore City Police Departmentgreen
ca4 · 1989 · cited in 1 West Virginia opinions naming this issue, 2022–2022
1 sentence

2022Servs., 682 F.3d 1, 9 (1st Cir. 2012) (“Equal protection claims tested by this rational basis standard . . . rarely succeed.”); Zombro v. Baltimore City Police Dep't, 868 F.2d 1364, 1376 (4th Cir. 1989) (Murnaghan, J., concurring in part and dissenting in part) (“Under rational basis scrutiny plaintiffs rarely prevail.”).

11
Parker v. Arizona Interscholastic Ass'ngreen
arizctapp · 2002 · cited in 1 West Virginia opinions naming this issue, 2022–2022
1 sentence

2022Parker v. Arizona Interscholastic Ass’n, Inc., 59 P.3d 806, 812 (Ariz. Ct. App. 2002) (“Because Parker is not a member of a suspect class. . . the rational basis test is the appropriate test to determine whether the transfer rule violated Parker’s equal protection rights.”). section ten of the West Virginia Constitution, and the scope and application of this protection is coextensive or broader than that of the fourteenth amendment to the United States Constitution.”).

11
Massachusetts v. United States Department of Health & Human Servicesgreen
ca1 · 2012 · cited in 1 West Virginia opinions naming this issue, 2022–2022
1 sentence

2022Servs., 682 F.3d 1, 9 (1st Cir. 2012) (“Equal protection claims tested by this rational basis standard . . . rarely succeed.”); Zombro v. Baltimore City Police Dep't, 868 F.2d 1364, 1376 (4th Cir. 1989) (Murnaghan, J., concurring in part and dissenting in part) (“Under rational basis scrutiny plaintiffs rarely prevail.”).

11
Lewis v. Canaan Valley Resorts, Inc.green
wva · 1991 · cited in 1 West Virginia opinions naming this issue, 2022–2022
2 sentences

2022See id. (“[A]ll other legislative classifications, including those which involve economic rights, are subjected to the least level of scrutiny[.]”).

2022Under the rational basis test, “the legislative classification will be upheld if it is reasonably related to the achievement of a legitimate state purpose.” Id.

11
Marcus v. Holleygreen
wva · 2005 · cited in 1 West Virginia opinions naming this issue, 2009–2009
2 sentences

2009Marcus v. Holley, 217 W.Va. 508, 523-24, 618 S.E.2d 517, 532-33 (2005)(citing U.S. Const. Amend. 14; W.

2009Marcus v. Holley, 217 W.Va. 508, 523-24, 618 S.E.2d 517, 532-33 (2005)(citing U.S. Const. Amend. 14; W.

11
Lonnie J. Shelton v. The National Collegiate Athletic Association, an Associationgreen
ca9 · 1976 · cited in 1 West Virginia opinions naming this issue, 2005–2005
11
In Re Paternity of NLMgreen
wisctapp · 1991 · cited in 1 West Virginia opinions naming this issue, 2002–2002
11
Geduldig v. Aiellored
scotus · 1974 · cited in 1 West Virginia opinions naming this issue, 2002–2002
11
Newport News Shipbuilding & Dry Dock Co. v. Equal Employment Opportunity Commissiongreen
scotus · 1983 · cited in 1 West Virginia opinions naming this issue, 2002–2002
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in West Virginia. Read the followed side critically anyway.

Also cited on this issue (24)

CaseCitedYears
Gibson v. West Virginia Department of Highways green
wva · 1991
2 sentences

2022Va. 596 , 425 S.E.2d 551 (1992); and Gibson v. West Virginia Department of Highways, 185 W.

1992In Gibson v. West Virginia Department of Highways, 185 W.Va. at 220, 406 S.E.2d at 446 , we recognized that under the rational basis test, the classification process is peculiarly a legislative function: “The Supreme Court expressed this point in Schweiker v. Wilson, 450 U.S. 221, 234 , 101 S.Ct. 1074, 1083 , 67 L.Ed.2d 186, 198 (1981), quoting Massachusetts Board of Retirement v. Murgia, 427 U.S. 307, 314 , 96 S.Ct. 2562, 2567 , 49 L.Ed.2d 520, 525 (1976): *603 ‘ “This inquiry employs a relatively relaxed standard reflecting the Court’s awareness that the drawing of lines that create distinct

31992–2022
Appalachian Power Co. v. State Tax Department green
wva · 1995
2 sentences

2021However, under the rational basis test, “which applies to all classifications not affecting a fundamental right or some suspect or quasi-suspect criterion[,] . . . a governmental classification will be sustained so long as it ‘is rationally related to a legitimate state interest.’” Id. at 594 , 466 S.E.2d at 445 (quoting City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432, 440 , 105 S.Ct. 3249, 3254 , 87 L.Ed.2d 313, 320 (1985)).

2021However, under the rational basis test, “which applies to all classifications not affecting a fundamental right or some suspect or quasi-suspect criterion[,] . . . a governmental classification will be sustained so long as it ‘is rationally related to a legitimate state interest.’” Id. at 594 , 466 S.E.2d at 445 (quoting City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432, 440 , 105 S.Ct. 3249, 3254 , 87 L.Ed.2d 313, 320 (1985)).

32000–2022
Atchinson v. Erwin green
wva · 1983
2 sentences

1986In Syllabus Point 7 of Atchinson v. Erwin, 172 W.Va. 8 , 302 S.E.2d 78 (1983), we elaborated on the rational basis test by stating: “Where economic rights are concerned, we look to see whether the classification is a rational one based on social, economic, historic or geographic factors, whether it bears a reasonable relationship to a proper governmental purpose, and whether all persons within the class are treated equally.

1986In Syllabus Point 7 of Atchinson v. Erwin, 172 W.Va. 8 , 302 S.E.2d 78 (1983), we elaborated on the rational basis test by stating: “Where economic rights are concerned, we look to see whether the classification is a rational one based on social, economic, historic or geographic factors, whether it bears a reasonable relationship to a proper governmental purpose, and whether all persons within the class are treated equally.

31986–1993
O'DELL v. Town of Gauley Bridge green
wva · 1992
2 sentences

2025In that matter, the SCAWV determined that the equal protection standard applicable to this type of challenge was the rational basis test set out in Syllabus Point 2 of O'Dell v. Town of Gauley Bridge, 188 W.

2022Petitioner does not explicitly state which constitutional provision or provisions West Virginia Code § 15-12-2(e)(1) violates, although petitioner does assert, “Under the Fourteenth Amendment to the United States Constitution and Section 10, Article III, of the West Virginia Constitution this Court has applied the ‘rational basis’ test when analyzing statutes under due process challenges.” Petitioner further asserts that “under the rational basis test, a law will be upheld so long as it is rationally related to a legitimate state interest.” In support of this position, he cites to the followin

22022–2025
Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co. green
wva · 1984
2 sentences

1993Where such classification is rational and bears the requisite reasonable relationship, the statute does not violate Section 10 of Article III of the West Virginia Constitution which is our equal protection clause.’ Syllabus Point 7, [as modified,] Atchinson v. Erwin, [172] W.Va. [8], 302 S.E.2d 78 (1983).” Syllabus Point 4, as modified, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., [ 174 W.Va. 538 ], 328 S.E.2d 144 (1984).’ Syllabus Point 4, Gibson v. West Virginia Department of Highways, 185 W.Va. 214 , 406 S.E.2d 440 (1991).” 8 The defendant argues that there is a rational ba

1993Where such classification is rational and bears the requisite reasonable relationship, the statute does not violate Section 10 of Article III of the West Virginia Constitution which is our equal protection clause.’ Syllabus Point 7, [as modified,] Atchinson v. Erwin, [172] W.Va. [8], 302 S.E.2d 78 (1983).” Syllabus Point 4, as modified, Hartsock-Flesher Candy Co. v. Wheeling Wholesale Grocery Co., [ 174 W.Va. 538 ], 328 S.E.2d 144 (1984).’ Syllabus Point 4, Gibson v. West Virginia Department of Highways, 185 W.Va. 214 , 406 S.E.2d 440 (1991).” 8 The defendant argues that there is a rational ba

21986–1993
State Ex Rel. Brewer v. Wilson green
wva · 1966
2 sentences

1977This Court recognized in Brewer v. Wilson, 151 W.Va. 113 , 150 S.E.2d 592 (1966), that the right to become a candidate for election to public office is a valuable and fundamental right.

1977This Court recognized in Brewer v. Wilson, 151 W.Va. 113 , 150 S.E.2d 592 (1966), that the right to become a candidate for election to public office is a valuable and fundamental right.

21977–1977
State Ex Rel. Longanacre v. Crabtree green
wva · 1986
1 sentence

2025Longanacre v. Crabtree, 177 W.

12025–2025
Carson v. Maurer red
nh · 1980
2 sentences

2025It is my firm belief, under the current rational basis test as established by the SCAWV, the decision in Whitlow might have gone the other way.4 4 Interestingly, one of the cases cited in Whitlow, the New Hampshire case of Carson v. Maurer, 424 A.2d 825 (N.H. 1980) (per curiam), did not utilize the rational basis test to strike down the statute in question.

2025Instead, it applied a “more rigorous judicial scrutiny than allowed under the rational basis test.” Id. at 830 .

12025–2025
O'NEIL v. City of Parkersburg green
wva · 1977
1 sentence

2025Va. 694 , 237 S.E.2d 504 (1977), set forth a rational basis test1 with a heightened level of scrutiny that is not consistent with the traditional rational basis test that federal courts and many, if not most, state courts have typically utilized when analyzing alleged Equal Protection violations.

12025–2025
Whitlow v. Bd. of Educ. of Kanawha Cty. green
wva · 1993
2 sentences

2025I am writing a concurrence in order to further develop why Whitlow v. Board of Education of Kanawha County, 190 W.

2025Va. at 231 , 438 S.E.2d at 23 , does not comport with the deference our state Supreme Court has more recently stated the rational basis test demands.

12025–2025
Federal Communications Commission v. Beach Communications, Inc. green
scotus · 1993
2 sentences

2022Petitioner does not explicitly state which constitutional provision or provisions West Virginia Code § 15-12-2(e)(1) violates, although petitioner does assert, “Under the Fourteenth Amendment to the United States Constitution and Section 10, Article III, of the West Virginia Constitution this Court has applied the ‘rational basis’ test when analyzing statutes under due process challenges.” Petitioner further asserts that “under the rational basis test, a law will be upheld so long as it is rationally related to a legitimate state interest.” In support of this position, he cites to the followin

2022Petitioner does not explicitly state which constitutional provision or provisions West Virginia Code § 15-12-2(e)(1) violates, although petitioner does assert, “Under the Fourteenth Amendment to the United States Constitution and Section 10, Article III, of the West Virginia Constitution this Court has applied the ‘rational basis’ test when analyzing statutes under due process challenges.” Petitioner further asserts that “under the rational basis test, a law will be upheld so long as it is rationally related to a legitimate state interest.” In support of this position, he cites to the followin

12022–2022
State v. Judge neutral
wva · 2012
1 sentence

2022Until such a change occurs, it will be necessary for the state police to amend their procedural rule[.]” 228 W.

12022–2022
Holt Civic Club v. City of Tuscaloosa green
scotus · 1978
2 sentences

2014Id., 439 U.S. at 70 .

2014Id., 439 U.S. at 70 .

12014–2014
Gregory v. Ashcroft green
scotus · 1991
2 sentences

2005Gregory v. Ashcroft, 501 U.S. 452, 471 , 111 S.Ct. 2395 , 115 L.Ed.2d 410 (1991) (quoting Vance v. Bradley, 440 U.S. 93, 97 , 99 S.Ct. 939 , 59 L.Ed.2d 171 (1979)).

2005Gregory v. Ashcroft, 501 U.S. 452, 471 , 111 S.Ct. 2395 , 115 L.Ed.2d 410 (1991) (quoting Vance v. Bradley, 440 U.S. 93, 97 , 99 S.Ct. 939 , 59 L.Ed.2d 171 (1979)).

12005–2005
Vance v. Bradley green
scotus · 1979
12005–2005
Clark v. Jeter green
scotus · 1988
2 sentences

2005In like fashion, the United States Supreme Court has explained that the rational basis test requires that the “classification must be rationally related to a legitimate governmental purpose.” Clark v. Jeter, 486 U.S. 456, 461 , 108 S.Ct. 1910 , 100 L.Ed.2d 465 (1988).

2005In like fashion, the United States Supreme Court has explained that the rational basis test requires that the “classification must be rationally related to a legitimate governmental purpose.” Clark v. Jeter, 486 U.S. 456, 461 , 108 S.Ct. 1910 , 100 L.Ed.2d 465 (1988).

12005–2005
Jane L. v. Bangerter green
utd · 1992
12002–2002
Evelyn Elisabeth Kirkhuff v. Robert P. Nimmo, Administrator, Veterans Affairs green
cadc · 1982
12002–2002
Heath v. Westerville Board of Education green
ohsd · 1972
12002–2002
Stephens v. RALEIGH COUNTY BD. OF ED. neutral
wva · 1979
11997–1997
Bernthal v. City of St. Paul green
minn · 1985
11992–1992
Leech v. Georgia-Pacific Corporation green
or · 1971
11992–1992
State Ex Rel. Heck's, Inc. v. Gates green
wva · 1965
11988–1988
Thomas v. United States green
scotus · 1985
11985–1985

Statutes the citing opinions construe

WV § W. Va. Code § 23-4-2 (3) WV § W. Va. Code § 29-12A-6 (3) WV § W. Va. Code § 55-2-6a (3) WV § W. Va. Code § 55-7B-4 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 630 (1980–2026) CA 364 (1976–2026) WA 223 (1973–2025) OH 222 (1975–2026) PA 209 (1973–2026) TX 197 (1975–2025) IA 185 (1977–2026) NY 173 (1973–2025) MI 147 (1959–2026) NJ 142 (1974–2026) CO 133 (1981–2026) FL 125 (1977–2025) MN 121 (1978–2024) KS 114 (1983–2026) AZ 97 (1978–2025) WI 97 (1979–2025) CT 88 (1980–2026) AR 79 (1983–2025) MD 77 (1973–2022) TN 75 (1976–2025) ID 60 (1980–2022) NH 60 (1975–2025) MA 59 (1977–2025) IN 57 (1974–2024) ND 52 (1979–2025) MO 51 (1978–2025) AK 50 (1973–2020) NM 50 (1983–2025) KY 50 (1992–2026) GA 48 (1980–2023) NC 46 (1974–2025) HI 45 (1972–2024) MT 44 (1981–2024) ME 39 (1978–2026) SC 37 (1990–2026) OK 33 (1984–2024) AL 29 (1980–2025) VA 28 (1984–2025) UT 27 (1978–2026) RI 24 (1979–2020) MS 22 (1994–2025) VT 21 (1980–2023) WV 20 (1977–2025) NE 18 (1986–2025) SD 17 (1987–2026) OR 17 (1988–2025) WY 17 (1982–2026) DC 16 (1977–2024) LA 16 (1984–2024) NV 15 (1975–2021) DE 15 (1978–2024) VI 6 (1987–2017) MP 2 (1989–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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