Grandparent Rights in Colorado Custody Cases with Joel Pratt | Episode 204

Exploring Grandparent Rights in Family Law: Insights from Joel Pratt

In this episode of Divorce at Altitude, host Ryan Kalamaya delves into the nuanced topic of grandparent rights within the realm of family law, joined by expert Joel Pratt, a partner at Daly and Pratt in Colorado Springs. This discussion unpacks the legal intricacies and real-life scenarios where grandparents seek custody or visitation rights, particularly amid familial disputes or parental challenges.

Episode Highlights:
- Understanding Grandparent Standing: Joel explains the legal concept of "standing" which determines a grandparent's eligibility to request custody or visitation in court.
- Constitutional Considerations: The episode explores how constitutional rights of parents can impact grandparent claims, referencing key legal precedents.
- Real-Life Scenarios: From drug abuse to disability, various situations are discussed where grandparents might step in to fill parenting gaps, highlighting both successful and challenging cases.
- Jurisdictional Issues: Joel discusses the complexities of cases that cross state lines, emphasizing the importance of jurisdiction in family law.

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Ryan Kalamaya and Amy Goscha provide tips and recommendations on issues related to divorce, separation, and co-parenting in Colorado. Ryan and Amy are the founding partners of an innovative and ambitious law firm, Kalamaya | Goscha, that pushes the boundaries to discover new frontiers in family law, personal injuries, and criminal defense in Colorado.

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DISCLAIMER: THE COMMENTARY AND OPINIONS ON THIS PODCAST IS FOR ENTERTAINMENT AND INFORMATIONAL PURPOSES AND NOT FOR THE PURPOSE OF PROVIDING LEGAL ADVICE. CONTACT AN ATTORNEY IN YOUR STATE OR AREA TO OBTAIN LEGAL ADVICE ON ANY OF THESE ISSUES.

Transcript

Ryan Kalamaya: 0:00

Welcome back to another episode of Divorce at Altitude. This is Ryan Kalamaya. We are continuing our journey through different issues related to family law that are not direct divorces, but are related in some capacity. And so we've had a previous episode on dependency and neglect with Amy Goscha. But this week, We're going to talk about grandparent rights and we are joined by Joel Pratt. He is a Colorado native. Joel, we'll get into how unique we we are these days as Colorado natives, but Joel received his bachelor's degree at the University of Colorado in Boulder at in English literature. And then he went on to the University of Michigan Law School and came back. We'll talk a little bit about that journey. He has experience in large civil law firms. He did his time in big law, as we call it in the legal industry, and now serves as partner in Colorado Springs at the law office of Daly and Pratt. In that role, he litigates appellate cases in all substantive cases. practice areas in trial court cases as a family lawyer. He specializes in legally and factually complex cases, whether due to constitutional and we'll get into constitutional issues in this episode or jurisdictional issues, as well as complex property disputes in custody cases. He has litigated several trials and appeals on behalf of grandparents, both in domestic and juvenile courts. Before I go on, Joel, welcome to the show. Thanks so much for having me, Ryan. I mentioned you were both Colorado natives and I did some background on you when we were talking off show. You went to Cherry Creek. Can you walk people through your journey into being a family lawyer and appellate attorney in Colorado Springs? Sure.

Joel Pratt: 1:58

Sure. I grew up in Southeast Denver, Colorado. I did go to Cherokee High School. I went to the University of Colorado at Boulder and after that I worked for a little bit and decided to go to law school and was lucky enough to get into the University of Michigan spent some time dealing with some cold and snowy winters in Michigan and and Enjoyed my time there other than the weather was really thrilled to be able to come back and work in in Denver for a little bit of time as you said, in big law with large civil litigation firms and then a position opened up with a with a lawyer who I had actually worked with as a staff member in the law firm before I had gone to law school, and it was a good fit to come back here, and I recently, in the last couple of years took over as a partner, as part of the business, so gone from working at the front desk to helping run the joint. It's it's been a great journey and I'm lovin it.

Ryan Kalamaya: 2:54

It's a full journey. I think I had a opposite educational background. I left Colorado and then came back for law school. But it's one of those things where you become jaded I think growing up here and you guys do some time outside the state to really appreciate how wonderful Colorado is. Is. We're going to talk about grandparent rights. And let's first start with one of the issues. It's a legal issue. For what's called standing. For listeners that don't know what standing is it comes up in grandparent cases. Can you explain to our audience what is standing and how does it come up in cases involving grandparents?

Joel Pratt: 3:38

Absolutely. Standing is It's a legal doctrine we hear about it often in the federal court context, but it comes up in grandparent rights cases a lot. Standing is just what us lawyers call the ability to walk into court and ask for something. Because you can't just walk into a courthouse and ask for anything. I can't go into a courthouse and ask for custody of somebody else's children. I can't go into a courthouse and just ask for somebody else to pay me. I have to have a reason to do that. I have to have a I have to be the right person to be asking for the right thing. And in grandparents rights cases, that comes up because parents have constitutional rights to the care and custody of their own children. And whether a grandparent has standing or the ability to come in and ask for an allocation of parental responsibilities is the first threshold question in any grandparent case.

Ryan Kalamaya: 4:31

And I should also back up maybe another step and even from a higher level Joel, we'll get into the practical applications, but when we say grandparent cases, what are we talking about? Can you give an example for those that may be unfamiliar?

Joel Pratt: 4:49

Sure, so there are lots of reasons that grandparents may be involved in cases. One typical reason is when you've got very young parents or inexperienced parents. Other situations are perhaps there is a dependency neglect case, which I know you covered on a previous podcast, where Parenting time has been allocated to a non parent, sometimes a grandparent and then sometimes you just have grandparents who, for whatever reason, have been involved for a long time whether it's because the parents have needed help or for other reasons and that, that grandparent involvement has morphed into a more parent like relationship, and it can come up in all kinds of contexts.

Ryan Kalamaya: 5:27

Yeah, and for listeners interested in learning more, we did have episode 85 where Amy and I talked about dependency and neglect cases. We'll refer to those and discuss those, but Joel, would you, a fair kind of example would be as, people to the podcast know we have an Eric and Melanie Wolf story, divorce story, but it would the example be where Eric and Melanie are going through a divorce and let's say that they're really young or, they might have so many issues in terms of alcohol or drug abuse or the conflict, but whatever the reason may be, if Eric's father calls you up and says, Hey, I know Eric and Melanie are going through a divorce. I'm worried about my grandchildren. I want to make sure I've, I'm really involved. I take them, seriously. I, skiing and I really enjoy skiing with my kid, my grandchildren I want to make sure that continues. Is that a scenario, one scenario where a grandparent could be involved in parenting issues?

Joel Pratt: 6:29

Sure. So I think that's a great example of the kind of calls we'll get sometimes where you'll have a grandparent who knows that there's some conflict going on between the parents. Their child and their child's spouse and they know that the grandkids are, they have some relationship with their grandkids and they want to know what they can do to preserve that. Do they need to, come into the case separately? How do they interact with the case? What kind of rights do they have? And what can they ask a court to do?

Ryan Kalamaya: 6:57

And going back to our standing issue what would the standing be for Eric's dad, for example a grandfather coming in? What, how does standing matter when the grandfather is asking for a particular kind of relief or asking, you questions. What are the things that you're going to get into with him?

Joel Pratt: 7:20

Sure. I think the first question for standing is is a factual question of what is grandpa's relationship like with the children? And what is his caretaking been of the children? So the baseline is that any natural grandparent or great grandparent has the ability to intervene in a custody case under the Children's Code, under Title 19. But under Title 19 can also intervene in domestic relations family law cases. And what the statute says is that the grandparent can intervene for the purpose of asking for visitation. My read of that statute is that's a relatively limited ask, is that a grandparent can ask for visitation. That does not mean a grandparent can ask for, I think, substantial parenting time or decision making, which is oftentimes when grandparents talk about their concerns about their kids, sometimes what they're really talking about is decision making. So that's the baseline level.

Ryan Kalamaya: 8:19

Baseline, so when, and that's really with regards to standing. So can you explain for listeners the kind of interrelationship or the differences with some constitutional issues in connection with standing?

Joel Pratt: 8:33

Sure. So the next level that a grandparent can ask for is there are certain times under Title XIV that a grandparent can ask for standing and can ask actually for an allocation of parental responsibilities, including an allocation of decision making. Those are generally cases, the way the common law doctrine was written, referred to them as psychological parent cases. They're 123 and What it really comes down to is, has the grandparent, for a substantial period of time defined in the statute as six months, actually taken on a parental role in addition to or separately from a child. The natural parents. And the way that interacts to answer your question with the constitutional standing issue is that there's this case out there from 2000 from the U. S. Supreme Court called Troxell v. Granville. And what Troxell determined was that natural biological parents have fundamental constitutional rights to the care and custody of their children that trump the rights of any non parent, and that includes a grandparent. And so the standing issue necessarily is the first step. It's a statutory analysis, but it's the first step in a constitutional analysis to make sure that anybody in the universe can't just walk into a court and intervene in a custody case and say, I want to have I want to have custody of these children. It limits the universe of people that can ask particularly for parenting time, but I think even, likely more importantly, decision making. Who's really making decisions? Who's parenting these children?

Ryan Kalamaya: 10:20

And an example might be where there's a dispute over going to school and the grandparents may just fundamentally disagree or health for example, we've had previous, guests on Katie Loom talk about the constitutional issues involved in decision making like vaccines, for example, as a hot topic. And there might be some issues. He walked us through just off the cuff with. If there's a dispute between Eric and his father, the grandfather, on whether or not the children should be vaccinated for COVID, for example how would that all work?

Joel Pratt: 10:59

Sure, so let's stipulate for the purpose of your hypothetical that Eric's father, for some reason, has standing to intervene in the case. So let's say that Eric's father has taken care of the child exclusively for the last six months and therefore has standing to intervene and actually ask for an allocation of parental responsibilities. Then the next step is that the constitutional analysis then really applies at the substantive stage. Under Colorado case law, the natural parent is going to be presumed to be acting in the child's best interest. Eric's decision about vaccines, whatever that decision is going to be given special weight. Eric's father then has the opportunity to rebut the presumption that Eric is acting in the child's best interest. And It's believed that the standard has to be at least clear and convincing evidence. So higher than a preponderance of the evidence standard, that's one of the ways in which the Constitution is acting here, is that the non parent has to then overcome that presumption by more than just a preponderance of the evidence. And then once that presumption has been overcome, if it's overcome by clear and convincing evidence, and it often is not in domestic relations cases, but if that presumption is overcome, then the court can make a decision about who's about whether Eric or Eric's father decision is in the child's best interest.

Ryan Kalamaya: 12:23

Got it. So it is, do you think it's fair to say that there's a, an abundance of Colorado case law that relies on Troxel in other contexts for essentially the proposition that parents there is a strong Weight or there is the courts really defer to biological parents in many contacts where Troxel applies and whether or not they're acting in the best interest of the children or are just fit parents in and of themselves.

Joel Pratt: 12:58

Because I have a contract with the Office of respondent parents counsel, I think I'm contractually obligated to say. That it's quite frequent in our case law that we see the troxel presumption overcome. And actually in the majority of cases in the dependency neglect context, the adjudication itself is the thing that overcomes the troxel presumption. But if we put those cases aside and we're really talking about domestic relations cases, then yes, there are there are a few cases and they uniformly do state that the that the parent's decision is presumptively in the children's best interests, and it's relatively rare to have a domestic relations court make a finding of unfitness against a natural parent who's not involved in the dependency neglect system.

Ryan Kalamaya: 13:44

So can you explain a little bit more about the rule, the DNN context and how that might differ from the domestic relations or like an ex, a divorce, for example? Sure.

Joel Pratt: 13:56

Sure and this is this is how so many grandparents rights cases come about, so we can walk through how that comes up. In a dependency neglect case, the initial step about whether the court really even has jurisdiction to do much of anything and order the parents to do anything, is the adjudication phase of the case. And at the adjudication phase of the case, it's determined whether the children are dependent or neglected. If the children are adjudicated dependent or neglected, At that point, the troxel presumption that a parent is acting in the children's best interest, at least under the law, is overcome. Now, a parent's fitness can be restored, and a finding of fitness does restore the troxel presumption even post adjudication, but there is a, but there is a legal presumption that once a child has been adjudicated, dependent, and neglected, absent a finding of rehabilitation and fitness that, that the troxel presumption has been overcome. That is why in dependency neglect cases, one of the ways that a dependency neglect case can close is the allocation of parental responsibilities, and that's often done to a non parent. And the reason a non parent is able is more likely to be given an allocation of parental responsibilities in a dependency neglect case is precisely because the troxel presumption has been overcome. In a family law case, you generally have two fit parents, or at least one fit parent, and maybe a grandparent or somebody else, but you have more of a civil dispute, not between the state and the parents, but between a number of private parties. And the private party with the most interest in a case like that instead of the state or instead of the child's welfare being paramount the parent's constitutional right and the parent's decision about their children is going to be given a lot more weight in the family law context. When things get The reason that cases tend to get really complicated is when a dependency neglect case closes with an allocation of parental responsibilities, that case is then certified into the domestic relations court and instead of being subject to Title 19, becomes subject to Title 14 and the modification provisions in the domestic relations law. So that's when things can get constitutionally quite complicated.

Ryan Kalamaya: 16:09

As just an example, and maybe for listeners that are having a hard time tracking, because Joel, you obviously know this inside and out but maybe it might be helpful to summarize. Eric and Melanie Wolfe there's some issue where they there's a dependency neglect case that is opened by the state the state then determines that the children between Eric and Melanie are dependent and neglected and looks elsewhere and Eric's father comes in and says, listen, like they're incapable of taking care of the kids right now and they start becoming more involved and they ultimately become the primary parents and that closes the DNN case. But then the, whatever the issues, oftentimes they're related between Eric and Melanie result in a divorce between Eric and Melanie. And, but meanwhile the grandparent, the Eric's grandfather is sitting there wondering what are the children going to do when they go back to, Eric and Melanie, and at what point is that this scenario that you just went over in terms of when you say APR, it can be both an allocation of parental responsibilities case, which is essentially a custody action between unmarried people, but it can also be relevant to a divorce in terms of allocation of parental responsibilities in a divorce, right?

Joel Pratt: 17:35

Correct. So I think what I would push back on in that example is What happens in the Eric and Melanie example, let's say that a simple example, Eric and Melanie both have problems with drug addiction and they're struggling with that and they're not able to take care of their child and Grandpa steps in, he's allocated parental responsibilities out of the dependency and neglect case and so he becomes the primary parent. Then Eric and Melanie, or at least one of them, maybe they get divorced and maybe one of them gets sober, gets treatment, gets sober, whatever. Solves the drug problem and takes care of the issues that led to the department's intervention and led to grandpa being the primary parent there, the the next step for Eric is not to go back to the Department of Human Services and say, I want my kids back. The next step for Eric is to actually go to the Domestic Relations Court and do a modification of parenting time, just like any parent in a divorce who wants to change the parenting time schedule under the law would. would go back to the Domestic Relations Court. Eric would do exactly the same thing and would actually file exactly the same form in the Domestic Relations Court and would ask the court to allocate him more parenting time and decision making now that he's become a fit parent, or now that he alleges he's become a fit parent.

Ryan Kalamaya: 18:49

Okay, so then what happens if any difference in the analysis or the issue if Eric and his dad are somehow aligned and that Eric wants his dad to be involved? What is, what happens in that circumstance?

Joel Pratt: 19:05

If you're, I think if you're representing Eric's dad, you, you then have an interesting choice to make because if they become aligned Eric's dad has, may have important information for the court, may have some good ideas about what's in the child's best interest, but if he and Eric are in agreement, then it may be best to have Eric be the primary advocate For whatever he wants, particularly if Melanie is involved on the other side and is still struggling with some of the problems that have, that had led initially to the APR to Grandpa so it, I often talk to my clients in these grandparent situations about the light touch approach, which is that particularly if you've got a a, an adult child who is parenting and who is aligned with your position, it may be better, from a constitutional and legal standpoint, to have that child take the primary position, because that person has the authority. All of the constitutional rights that the grandparent does not.

Ryan Kalamaya: 20:06

And we talked about this in listeners may recall with Katie Loom in terms of the relief requested and it's the ends justify the means. Or, form over substance, whatever you want to call it, but what I'm hearing you say is Eric and his dad could say Eric can get, primary care of the children, and then that allows him to delegate or his father's going to be more involved during Eric's time and that, that might be an easier path for Eric's father to exercise his grandparent rights as opposed to Eric's grandfather intervening and trying to get involved directly because there might be some constitutional or other hurdles to his him being allocated any sort of responsibility for the children.

Joel Pratt: 20:59

That's precisely right. And the thing I would add to is that. And then as both a grandparent and a grandparent's counsel the next thing to think about is my presence in this case causing more conflict or is it solving more conflict? Because if if the grandparent has a particularly negative relationship with the other party, the adverse party stepping back may be the thing that allows, the conflict to calm down. In other cases, grandparents can be calming influences, but especially if there's been either a history of domestic violence or any kind of other history of really high conflict between the two parents. Sometimes grandparents are the folks who can really step in and, turn the heat down on the conflict and when that occurs oftentimes it's good to have the grandparent. Certainly not coming in guns blazing, with their, torch and pitchfork knocking at the door. But certainly have the grandparent continue to be involved in a formal way to, to keep things calm.

Ryan Kalamaya: 21:59

How would you, Joel, how would you describe just in general rights for grandparents in Colorado?

Joel Pratt: 22:06

I think grandparents have fairly limited rights. I think, the primary right that they have is granted under Title 19, which is just to ask for visitation but there's no guarantee they can even get that because if they if two parents who are both fit say, we don't want to have grandparents with separate visitation there's not a lot the court is going to do about that. The court is going to have to make some special finding for a grandparent, even in that situation and then Aside from that, unless a grandparent has really acted as a parent and has really been deeply involved standing in the shoes as a parent, they may not be able to even ask the court for anything, let alone be granted something.

Ryan Kalamaya: 22:45

Can you, for, listeners, could you give maybe some examples of situations in which the courts have looked favorably upon grandparents intervening or otherwise? And, just so people understand, what are examples of grandparents who are, having valid, recognized rights in Colorado?

Joel Pratt: 23:10

Sure. I think I think it ranges from, Parents who are struggling with issues like domestic violence and drug abuse there are also I have seen and worked on cases where the parents are have some kind of disability where they can do some parenting but not not all of the parenting. Where both parents and the children have some kind of either mental or physical limitation and the parent's limitation doesn't allow them to take care of the children's limitation. So there are those are the situations in which, where grandparents step in to fill gaps that the parents have. Those are really the situations in which courts are look favorably on grandparent intervention. And I'd contrast that to when you have a grandparent who, just has a contentious relationship with their children and can't always work out parenting time as, especially as, maybe things fall apart in their, in the parents marriage and the grandparents are getting even more cut out or having, even more conflict with both their child and their soon to be ex in laws. Those are situations in which the court is going to look less favorably, I think, on grandparent intervention.

Ryan Kalamaya: 24:20

We talked about throwing a another scenario out to flesh out this idea before we started recording and I think it might be helpful for people to understand just how crazy sometimes our cases are and, one example is what if Eric calls you Joel and says, listen, I've got a 16 year old son and he just got an 18 year old girl pregnant and she. His, she was here bold in Boulder. They live in Boulder and she's gone back to California. She was just visiting a friend at CU Boulder where, we both went to school for a period of time. And what if Eric calls you in that circumstance? Can you walk us through some of the issues, if he's a grandparent, admittedly a young grandparent what are the kind of issues that he's gonna have to navigate? Because I know that one. thing in your bio and we, have discussed offline is, the jurisdictional issues and we've talked a little bit about that with the UCCJEA with Brian Walters is a previous episode, but walk listeners through some of the issues with grandparent rights and jurisdiction cause I know you deal with some of those issues that are sometimes inter related.

Joel Pratt: 25:38

Sure. And I'll I'll just back up and say one of the most interesting things about doing grandparent cases is you often get all of the issues that are legally complex, layered in a single case. And that's both constitutional, statutory, jurisdictional, it's all in there. That's what can be make working on them both infuriating and super interesting. So the, in, in the scenario you provide I think the first. Overarching question is, which court is going to hear this case? So you've got, if you have somebody who had been here visiting, but the child's not born yet and she goes back to California, and it's assumed that the child is going to be born in California when the child is born, California is the child's home state. And Without without some other jurisdictional hook or some other agreement the home state jurisdiction is going to apply, and the California court is very likely to take jurisdiction, and the Colorado court is very likely to defer to the California court, even if both parents file on the same day the In the various jurisdictions. The answer to to Eric in that situation is you should probably go call a lawyer in the county in which the, in which, mom just moved to, because that's going to be the place that where this is going to be heard. Now, if the situation is switched and we're in Colorado then the analysis we've just been talking about, about, about the fitness of the parents is going to come into play but even those grandparents presumptively are not going to start with any rights other than the right under 19 11 17 for visitation.

Ryan Kalamaya: 27:09

Yeah, and for the listeners they know that I'm an avid skier and Bodie Miller, the Olympic skier, he actually had it was several years ago, but there was an issue where he got a girl pregnant in California and then she moved to New York and there was some interstate, really complex litigation over Which state and whether an unborn child, you could file a paternity or some sort of custody action for an unborn child. But let's assume that, she moves from Boulder to Colorado Springs. How would that change or what would the steps be for Eric Wolf as a grandparent once the child is born?

Joel Pratt: 27:53

So the first thing for Eric is that if there's not a custody case between the parents, there's really nothing for him to do because he's not going to have standing to open a case under and file a petition under 14. 10 123 and the which is the grandparent standing for allocation parental responsibility statute and the children's code the title 19 request requires there to already be an open case. So the answer is he's going to have to wait for the two of them to figure out how they want to handle custody if they're going to try to be together if they're going to be separate. If they're going to if there's going to be some allocation of parental responsibilities and if there's going to be a contested case at all, because if the two of them agree there's really not a whole lot for Grandpa, in this case Eric, to do in that case. It's going to be it's he's going to have to rely a lot more on his skills as a parent of his own child than on the court system.

Ryan Kalamaya: 28:51

Yeah, and Joel, talk to me about the dynamic between representing Eric and his son or both of them at the same time or how that plays out because there might be an alignment of interest. We talked about that earlier. But what happens with the scope of representation and who you're representing or could potentially represent in that scenario?

Joel Pratt: 29:16

So it's generally my practice not to not to dual represent in those cases because of the danger of conflict is too high. And then the parties have invested. Time and resources, and getting me up to speed, and me helping them. And then if they get crossways, I have to just walk away from the case under our ethics rules. Under that circumstance, my, my general approach would be to represent Eric's son because that's the person with an interest. And then if Eric wanted to be involved, provided he continued to be aligned. I often do work with whether they're, young parents or older parents, grandparents are often somewhere in the background of cases, and so I'm often getting information and things. from folks like that, but I don't enter any kind of formal representation of that person because of the danger of adverse representation. If there's adversity or there's presumptive adversity or I see signs of that, I will often just encourage that grandparent to go get another lawyer so that we just have somebody who we're all working with early on. But as a general rule, I won't be able to represent both, and I won't be very clear about that up front.

Ryan Kalamaya: 30:22

So you can have Eric's son waive his attorney client privilege for purposes of discussing the case with Eric and essentially try to help out the whole family, but there may be a circumstance in which you'll take the son and then bring in another lawyer to represent Eric in that circumstance?

Joel Pratt: 30:44

Correct. Or sometimes I'll get contacted by Eric's son's lawyer will call me and say, Hey, grandpa needs an attorney. Are you willing to come in and and work on that side so that we avoid any conflict. And all these, and these conversations can happen between lawyers. So I've come at it from both sides. But that's generally how I'm going to approach it.

Ryan Kalamaya: 31:03

Joel, for any grandparents or other people that want to learn more about you will have links to your bio in the show notes and your other information related to you, but can you tell people where they can find you if they want to find out more about you and your practice?

Joel Pratt: 31:20

Absolutely. My website is dailypratlaw. com, that's D A I L E Y. P R A T L A W dot com. My email is just my first name, Joel, J O E L, DailyPratLaw. com. And the phone number for the firm is 719 473 0884.

Ryan Kalamaya: 31:43

Joel, I appreciate the time. I as listeners and probably evidence of my questioning, I don't know that much about grandparent rights. So it's always interesting to learn more and, certainly we'll be reaching out to you on any cases involving grandparent rights. But until next time, thank you. And that is going to be a wrap. Thanks so much. I really enjoyed it. hey everyone. This is Ryan again. Thank you for joining us on Divorce at Altittude. If you found our tips, insight, or discussion helpful, please tell a friend about this podcast. For show notes, additional resources or links mentioned on today's episode, visit Divorce at Altittude dot com. Follow us on Apple Podcasts, Spotify, or wherever you listen in. Many of our episodes are also posted on YouTube. You can also find Amy and. Law or 9 7 0 3 1 5 2 3 6 5. That's aaa.