If I can butt in: I believe that traditional notions of domicile require intent to remain as a resident; physical presence may establish domicile for purposes of personal jurisdiction, but it is sufficient rather than necessary. Every person must have one and only one domicile. Intent to remain, is usually determined by common-sense factors – where one receives mail, where one hold bank accounts, where one’s driver’s license is issued, where one is employed/goes to school, ect. One’s first domicile remains his domicile absent positive expression of intent not to remain permanently in that jurisdiction.
It seems to me that its just a simple matter of determining Emanuel’s last known domicile (obviously Illinois/Chicago) and then considering whether he manifested any positive intent NOT to remain a permanent resident of that locale. Whether he owned or rented a residence in Chicago doesn’t seem to me dispositive. If my employer sends me to India for six months to train customer service reps, I would likely end my lease and put my things in storage, but that doesn’t mean I intend to change my place of residence. Why should leaving for a year, or four years, or eight years be any different – its a set period of time that you intend to be away for for a specific purpose, but you do not intend to permanently change your residence.
DISCLAIMER: I haven’t looked at the decision at all, just talking off the top of my head.