The quantity J is not path-independent for monotonic mode I and mode II loading of elastic-plastic materials, so only a contour very close to the crack tip gives the energy release rate. Also, Rice showed that J is path-independent in plastic materials when there is no non-proportional loading. Unloading is a special case of this, but non-proportional plastic loading also invalidates the path-independence. Such non-proportional loading is the reason for the path-dependence for the in-plane loading modes on elastic-plastic materials.