Kerista Commune in San Francisco. Difficulties Morin (1999) and Fleckenstein (2014) noted that certain conditions are favorable to good experiences with polyamory, but that these differ from the general population. Heavy public promotion of polyamory can have the unintended effect of attracting people to it for whom it is not well-suited. Unequal power-dynamics, such as financial dependence, can also inappropriately influence a person to agree to a polyamorous relationship against their true desires. Even in more equal power-dynamic relationships, the reluctant partner may feel coerced into a proposed non-monogamous arrangement due to the implication that if they refuse, the proposer will pursue other partners anyway, will break off the relationship, or that the one refusing will be accused of intolerance. Polyamorous relationships present practical pitfalls. One common complaint from participants is time management, as more partners means one must divide one's time and attention up between them, leaving less for each. Related is that the complexity of the arrangement can lead to so much effort being spent on the relationship that personal, individual needs can be overlooked. The strong emphasis on communication can unintentionally marginalize partners who are less articulate. Finally, negotiating the sometimes complex rules and boundaries of these relationships can be emotionally taxing, as can reconciling situations where one partner goes outside those boundaries. Some therapists argue that polyamory is not good for relationships, saying it is a "recipe for hurt, disappointment, jealousy, and breakups". Legal issues and legal recognition In 1998, a Tennessee court granted guardianship of a child to her grandmother and step-grandfather, after the child's mother April Divilbiss and partners outed themselves as polyamorous on MTV. After contesting the decision for two years, Divilbiss eventually agreed to relinquish her daughter, acknowledging that she was unable to adequately care for her child and that this, rather than her polyamory, had been the grandparents' real motivation in seeking custody. In 2010, Ann Tweedy, a legal scholar, argued that polyamory could be considered a sexual orientation under existing United States law. This argument was opposed by Christian Keese, who wrote in 2016 that advocating a "sexual orientation model of polyamory is likely to reduce the complexity and transformative potential of poly intimacies," while also limiting the reach and scope of possible litigation, obstructing the ability of poly activists to form alliances with other groups, and increasing the possibility that poly activists will have to settle for legal solutions