⌛ Julie Annas Expansive Theory Of Justice

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Julie Annas Expansive Theory Of Justice

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Justice as Fairness

In these circumstances, a GVR might well result in the panel concluding that the principles most recently reaffirmed in Puckett require a departure from the approach announced in Torres and applied in this case. That ruling would eliminate the need for this Court to expend its own scarce resources by hearing and resolving this case on the merits. The petition for a writ of certiorari should be gran ted, the judgment of the court of appeals should be va cated, and the case should be remanded for further con sideration in light of Puckett v.

The indictment charged, and the government's proof showed, a course of conduct that began before the enactment of the forced-labor statute and continued thereafter. Criminal statutes are presumed not to have retroactive effect, see Johnson v. But if the jury relied on non-criminal, pre-enactment conduct in reaching its verdict, then respondent may have been found guilty of a non-crime, which would appear to violate the Due Process Clause. See Burge v. Butler, F. The proper characterization of the error in this case, however, does not affect the plain-error analysis. In either case, the jury would have been given the option of finding respondent guilty on both a valid theory post-enactment violation or an invalid theory pre-enactment violation.

This Court's recent decision in Hedgpeth v. Pulido, S. Accordingly, the panel's decision to apply an "any possibility" standard here is wrong, regard less of how the error is characterized. But see App. Marcus argues, inter alia, that his conviction amounted to a violation of the Ex Post Facto Clause of the Constitution. For the reasons set forth below, we agree. The judgment of the District Court is vacated, and the case is remanded to the Dis trict Court for proceedings consistent with this opinion.

See United States v. Marcus, F. We recite only those facts relevant to the Ex Post Facto challenge. Jodi returned to Joanna's apartment in Maryland for a second visit in November After her second visit, Marcus convinced Jodi to move from the Midwest to Maryland, where she would live with Joanna. If I beg you for my release, Sir, please ignore these words. Jodi moved into Joanna's apartment in January , and Marcus visited them in Maryland every one to two weeks. At some point, Marcus instructed Jodi to convince her younger sister to travel to Maryland, and when she refused, Marcus told her that she would be severely punished. In October , Marcus arrived in Maryland to inflict Jodi's punishment.

He handcuffed her to a wall and left to take a nap, informing her that he would re turn to inflict the punishment. Jodi testified that at this point, she had a moment of clarity and decided to leave Marcus. She convinced Celia to help her off the wall, but Joanna awakened Marcus. Jodi told Marcus that she wanted to leave, and in response, Marcus inflicted upon Jodi the most severe punishment she had ever re ceived up to this point.

The incident was photographed for Marcus's website. With Jodi listening on the line, Marcus threatened that he would show Jo anna's pictures to her family and that he would harm members of her family if she were to leave him. Jodi testified that, as a result of having heard this conversa tion, she thought that Marcus would do the same to her were she to leave. Marcus received all site-related revenues, which con sisted primarily of membership fees and advertising. During the time that Jodi lived with Rona, Marcus con tinued to engage in violent sexual behavior with her, punishing her severely when he was unhappy with her work on the website. Jodi testified that each of these incidents was non-consensual, but that she was afraid to leave him.

At one point, when she told Marcus that she wanted to leave, he threatened to send pictures to her family and the media. Finally, in March , Marcus told Jodi that she would be allowed to leave him, but that she had to en dure one final punishment. He drove her to the home of a woman named Sherry and there inflicted severe pun ishment upon Jodi, including banging her head against a beam in the ceiling of Sherry's basement, tying her hands and ankles to the beam, beating her and whipping her while she was hanging from the beam, drugging her, and having sexual intercourse with her. He photo graphed the incident and forced Jodi to write a diary en try about the incident for his website. Jodi continued to live with Rona until August , when Rona told Mar cus that she no longer wanted Jodi to live with her.

Jodi moved into her own apartment, and her interactions with Marcus became less frequent, although she re mained in contact with him until On February 9, , the government filed a super ceding indictment, charging Marcus with violating the sex trafficking statute, 18 U. At the time, Marcus did not object to the jury instructions on this ground, and he did not raise any argument to this effect in his motion for a judgment of acquittal under Fed. Because Marcus failed to raise this argu ment before the District Court, it is reviewed for plain error. Villafuerte, F. The Supreme Court has interpreted this clause as prohibiting Congress from passing a law that: 1 makes an act a crime that was legal when commit ted; 2 makes a crime greater than it was when it was committed; 3 increases the punishment for a crime after it has been committed; or 4 deprives the accused of a legal defense that was available at the time the crime was committed.

It is undisputed that the indictment charges Marcus with violating the statute between January and October , that the government presented evidence at trial with respect to this entire time period, that the TVPA was enacted in October , and that the District Court failed to instruct the jury with respect to this is sue. This case, therefore, clearly implicates the Ex Post Facto Clause. However, the government argues that the sex trafficking and forced labor offenses constitute con tinuing offenses, and that even though the criminal con duct at issue began prior to enactment of the TVPA, it continued after enactment; accordingly, no violation oc curred here. Marcus argues that the sex trafficking and forced labor offenses do not constitute continuing offenses.

We need not decide whether the offenses constitute continuing offenses for Ex Post Facto purposes because, even if they do, the convictions violate the Ex Post Facto Clause. In Torres, we stated that, even in the case of a continuing offense, if it was possible for the jury-who had not been given instructions regarding the date of enactment-to convict exclusively on pre-enactment conduct, then the conviction constitutes a violation of the Ex Post Facto clause. See also United States v. This is true even under plain error review. See Torres, F. Accordingly, the application of the TVPA in such a manner constituted an Ex Post Facto Clause violation, and the conviction must be vacated under our holding in Torres.

We write separately because we be lieve this Court's precedent with regard to plain-error review of ex post facto violations does not fully align with the principles inhering in the Supreme Court's re cent applications of plain-error review. If all three conditions are met, an appellate court may then exercise its discretion to notice a for feited error, but only if 4 the error seriously affect[s] the fairness, integrity, or public reputation of judicial proceedings. Our case law appears to conflict with this precedent because it requires a retrial when ever there is any possibility that an improperly instruc ted jury could have convicted a defendant based exclu sively on conduct committed prior to the enactment of the relevant statute, see United States v.

We write to bring this issue to our Court's attention and to explain how this difference af fects the outcome of this appeal. One element of that crime-the materiality of the defendant's false statement-was un constitutionally decided by the trial judge, rather than by the jury. See Johnson, U. Gaudin, U. Likewise, in Cotton, the defendants were convicted of conspiring to distribute and to possess with intent to distribute a detectable amount of cocaine and crack co caine. The indictment, however, failed to allege drug quantity, a fact that increased the statutory maximum penalty, rendering the defendants' enhanced sentences unconstitutional.

See Cotton, U. New Jersey, U. We see no reason why this principle should not apply to the context of ex post facto violations. See, e. Loui siana, U. Thus, where there is no reasonable possibility that an error not objected to at trial had an effect on the judg ment, the Supreme Court counsels us against exercising our discretion to notice that error. In other words, the defendant must meet the low threshold of offering a plausible ex planation as to how relevant pre- and post-enactment conduct differed, thereby demonstrating a reasonable possibility that the jury might have convicted him or her based exclusively on pre-enactment conduct. When this requirement is not met, the error does not seriously af fect the fairness, integrity, or public reputation of the judicial proceedings.

Our standard-announced in Torres, F. Our Court has never directly ad dressed this possible conflict. Indeed, our opinion in Torres preceded the Cotton and Johnson decisions, and we did not apply the Supreme Court's current four-part plain-error analysis in crafting our standard. Accordingly, our Court may wish to reexamine its prece dent to ensure that it does not conflict with Supreme Court precedent. The sex-trafficking statute makes it illegal to knowingly, in or affecting interstate commerce, recruit, entice, harbor, transport, provide, or obtain by any means a person knowing that force, fraud, or coercion will be used to cause the person to engage in a commer cial sex act.

The government alleged that Marcus engaged in several trafficking activities with the requisite mens rea: 1 that he recruited, en ticed, and obtained Jodi when he met her online in late ; 2 that he transported Jodi from Maryland to New York in January ; and 3 that he harbored Jodi from until Only the harboring activity occurred after the October effective date of the statute. Thus, if the jury concluded that Marcus did not harbor Jodi within the meaning of the statute,11 but did recruit, entice, or obtain her in or transport her in , it would have convicted him based only on pre-ena ctment conduct. This material difference in conduct demonstrates a reasonable possibility that the jury may have relied exclusively on pre-enactment conduct. Un der such circumstances, a retrial is necessary.

In contrast, with respect to the forced-labor convic tion, Marcus has no plausible argument as to why the jury would have differentiated between his conduct be fore and after the enactment of the statute. Here, the government alleged that from January until at least the spring of , Marcus forced Jodi, through threat of serious physical harm and actual physical harm, to create and maintain a commercial BDSM web site. Jodi testified that throughout this time period she was forced to work eight to nine hours a day maintaining the website and that Marcus would punish her whenever she failed to update the site quickly enough.

In other words, a rational jury would have ei ther convicted Marcus for his conduct during this entire period or not at all. Because the district court's error in failing to instruct the jury on the Ex Post Facto Clause did not seriously affect the fairness, integrity, or public reputation of the judicial proceedings, his conviction should not be vacated for this error. Nevertheless, we join the per curiam opinion in va cating both of Marcus's convictions because the Torres standard remains the law of this circuit. See Bd. Hufstedler, F. For the reasons discussed, however, we believe that our precedent warrants reexamination. Defendant Glenn Marcus was tried before a jury on charges of sex trafficking, in violation of 18 U.

At trial, the complaining witness testified that she en tered into a consensual BDSM relationship with the de fendant, who subsequently used force and coercion to prevent her from leaving when she sought to do so. She testified that she remained with the defendant against her will for nearly two years, during which period she created and maintained the defendant's website and engaged in BDSM conduct with the defendant and oth ers that was photographed and placed on the website. On March 5, , a jury found the defendant guilty of sex trafficking and forced labor and not guilty of dissem ination of obscene materials.

The jury also found that the government had proved the defendant committed aggravated sexual abuse in relation to the forced labor count, a statutory aggravating factor. Defendant now renews his Fed. The defendant raises three grounds for setting aside his conviction. Third, he argues that the government has failed to pres ent sufficient evidence for a reasonable jury to find a nexus between the force or coercion employed by the defendant and the commercial sex act element of his sex trafficking conviction or the labor or services element of his forced labor conviction.

In the alternative, defen dant moves for a new trial pursuant to Fed. For the reasons stated below, the defendant's motions are denied. Autuori, F. Events from to June In , Jodi,15 the complaining witness, learned about BDSM on the internet and began visiting online chatrooms to find out more information. At the time, Jodi un derstood BDSM to be a type of relationship in which, within certain guidelines and limits, one person is domi nant and the other submissive. See id. He explained to Jodi that, in the type of BDSM he practiced, he did not allow the use of any limits or safe words. By way of example, he explained that he could decide to cut off a slave's limb or order her to kill a small child. In subsequent conversations by telephone, the defendant communicated to Jodi that she belonged to him and needed to serve him.

During these early encounters with the defen dant, Jodi shared intimate details about her life experi ences, including that she had been physically and emo tionally abused by her mother and had struggled with an eating disorder. In October , Jodi traveled from her home in the Midwest17 to Joanna's apartment in Maryland to meet the defendant. In November , Jodi again traveled to Mary land to meet the defendant. During these two visits, the defendant complimented Jodi on her looks and performance of BDSM activities.

He also continued to emphasize that she belonged to him and needed to be with him. After Jodi's second visit, the defendant informed her that he wanted her to move to Joanna's apartment in Maryland and Jodi agreed to do so. Prior to moving, Jodi submitted a petition, which she drafted and Joanna edited, in which she asked the defendant to allow her to serve him as his slave. If I beg you for my release, Sir, please ig nore these words.

Despite this request, however, Jodi believed that she would be able to leave if she wanted to do so, because the defendant had previously told her that he never wanted to have a slave who did not want to serve him. See Tr. The defendant, who lived in Long Island, New York at the time id. When the defendant was present, Jodi and any other women present were not allowed to wear clothing, could not eat, drink or speak without permission, were only allowed to sleep for a couple of hours at a time, and were expected to follow the defendant's instructions.

The branded skin subsequently developed into a severe burn, but the defendant did not permit Jodi to seek medical attention. The defendant also prohibited Jodi from maintaining any of her prior friendships and required her to receive permission from him to speak with her family. He told her that she was ugly, stupid, and disobedient and did not deserve to be his slave. For example, Jodi was whipped, choked, and had sexual intercourse while tied to a wall. At the time, Jodi found some of these activities to be sexually gratify ing.

When the defendant was not present at the apart ment, Jodi and Joanna were expected to ensure that each was complying with his instructions. The defendant would also direct Joanna or Jodi to wear butt plugs19 or breast clamps for long periods of time. If either failed to follow in structions, the other one would inform the defendant and he would either administer punishments himself or order one to punish the other.

Jodi was pun ished nearly every time she saw the defendant, including being whipped or placed in a large, metal dog cage in the apartment. Several months after Jodi began living at Joanna's apartment, the punishments inflicted by the defendant became increasingly severe, and Jodi began feeling de pressed. In June , she burned her arm twice with a cigarette. Fearing that the defendant would notice the burns when he visited from New York, she told him on the telephone what she had done.

He instructed Joanna to burn herself with a cigarette on her arm and then to punish Jodi by defecating on her face in the bathtub and making her clean the bathtub with her tongue. He then burned her with a cigarette all over her body, in cluding her forehead, arms, the bottom of her feet, the back of her neck, and inside her vagina. While Jodi was miserable because she believed she had disappointed the defendant, she continued to remain in the relationship because she believed she could do better and that she belonged with him.

Jodi was also directed to use the internet to recruit a new slave to join them in Maryland. Because Jodi re fused to complete the first task and was unsuccessful with the second, the defendant told her that, the next time he visited, she would be so severely punished that she might not be able to work for some time afterwards. In October , the defendant arrived in Maryland, where he handcuffed Jodi to the wall and told her that he would punish her after he took a nap.

While she was on the wall, Jodi testified that she had a moment of clarity and decided that she wanted to leave. She told Celia, another woman serving the defendant, and Celia helped her get down. Joanna awakened the defendant, who ordered that Jodi be returned to the wall. When Jodi informed the defendant that she wanted to leave, he told her to shut up. He then put a whiffle ball inside her mouth, closed her lips shut with surgical needles so that she was unable to speak, and placed a hood over her head. While she was on the wall, he whipped and beat her with a cane extremely hard for an extended period of time and had sexual intercourse with her. The defendant then took Jodi off the wall and attached her with handcuffs to a flat board, at which point he attempted to sew Jodi's vagina closed using a sewing needle and thread, only stopping when the needle broke.

A butt plug was in serted into her anus Govt. While this incident was taking place, Jodi was crying and screaming. The abuse was photographed and Jodi had to write a diary entry about it, and these were placed on the de fendant's website. This was the most extreme punish ment to which Jodi had ever been subjected. Prior to this experience, Jodi believed that she would be able to leave any time she wished. She no longer wished to be involved with the defendant and remained with him only out of fear. In November , Joanna told the defendant that she no longer wanted to serve him. While both Jodi and Joanna were on the telephone with the defendant, he threatened to send photographs and a vi deotape of Joanna engaged in sexually explicit behavior to her father and to kill her godson if Joanna did not continue to serve him.

As a consequence, Jodi became terrified that, if she at tempted to leave the defendant, he would send pictures to her family or harm one of her family members. In January , the defendant instructed Jodi to move to New York and stay at the apartment of a wo man named Rona, who, Jodi was told, had been his slave since she was 13 years old. After creating the website, Jodi worked on it approximately eight to nine hours a day, updating photographs and diary entries and clicking on banner advertisements to increase revenue and enhance its visibility on the internet.

Although she did not want to work on the website, she continued to do so because she was terrified of the consequences if she refused. The defendant punished Jodi if she failed to post diary entries or pictures quickly enough or if the website made less money than he ex pected. In April , when the defendant was dis pleased with Jodi's work on the website, he put a safety pin through her labia and attached a padlock to it, clos ing her vagina.

In an attempt to stop Jodi from screaming and crying during this incident, Rona put a washcloth in Jodi's mouth and the defendant whipped her with a knife. The defendant photo graphed this incident and the pictures were placed on the Slavespace website. See Govt. All revenues made from the website went to the de fendant. The defendant made several hundred dollars per month from the member section of the site and an additional several hundred dollars from advertising. During this period, the defendant continued to pun ish Jodi severely. For example, he once whipped Jodi so hard that she vomited. He also held a plas tic bag over her head until she passed out. In another incident, he zipped Jodi into a plastic gar ment bag and choked her through the plastic.

Each of these incidents was non-consensual and each was photographed for the website. However, Jodi continued to stay with the defendant be cause she was terrified of his reaction if she left and feared that he might publicly expose her. At one point, when she expressed to him how unhappy she was, the defendant threatened to send photographs of her to her family and the media. In March , Jodi called the defendant and told him that she wanted to leave, and he told her that she would first have to endure one final punishment.

Even though she was terrified, she agreed to do so because she feared the consequences if she did not comply. The defendant drove her to the Long Island residence of a woman named Sherry, in structed her to take off her clothes, and then directed her to go to the basement. As she was descending to the basement, Jodi realized that she could not go through with the punishment and the defendant forced her to go down the stairs. Jodi started to scream and the defendant banged her head against a beam in the basement, bound her hands and ankles and attached her to the beam.

He then beat and whipped her for over an hour. While he was beating her, he told her that she belonged to him and needed to serve him. He made her take a valium id. Jodi continued to try to scream, even with the needle in her tongue. The defendant then left her suspended for half an hour or 45 minutes, until her feet and hands became completely numb. After letting her down, he took her to a bedroom and had sexual intercourse with her.

The defendant photographed Jodi throughout the punishment and forced her to write a diary entry about it to post on his website. Jodi testified that, after this incident, she felt broken and terrified and as if there was no way she would be able to leave the relationship. She continued to live in Rona's apartment until August Events from August to In August , Rona communicated to the defen dant that she did not want Jodi to live in her apartment any longer, and the defendant allowed Jodi to move out. When Jodi obtained her own apartment, her interactions with the defendant became less frequent and less extreme.

However, she continued to stay involved with the defendant in order to maintain a semblance of control over his use of her pictures on the website. During this time period, the defendant posted diary entries on the website exposing personal information that Jodi had told him about her family. Jodi maintained contact with the defendant until Rule 29 Motion The defendant asks the court to set aside his convic tions under Rule 29, contending that 1 the rule of len ity requires that the sex trafficking and forced labor statutes be construed narrowly and, therefore, are inap plicable to the conduct at issue; 2 the sex trafficking statute does not apply when the victim is coerced into pornography as opposed to prostitution; and 3 the evi dence is insufficient to show a nexus between the defen dant's conduct and the commercial sex act element of the sex trafficking statute or the labor or services ele ment of the forced labor statute.

Standard of Review A defendant seeking a judgment of acquittal on the ground that the evidence was insufficient bears a heavy burden. Russo, 74 F. Au tuori, F. The court must also give deference to the jury's assessment of the credi bility of the witnesses and to its selection among com peting inferences. Pelaes, F. Virginia, U. Guadagna, F. Applicability of the Trafficking Victims Protection Act to the Conduct for which the Defendant was Con victed The defendant invokes the rule of lenity to contest the applicability of the sex trafficking and forced labor statutes to the conduct about which evidence was ad duced at trial. As the Supreme Court explained, ambiguity concerning the ambit of criminal statutes should be resolved in favor of lenity. This principle is founded on two policies that have long been part of our tradi tion.

First, a fair warning should be given to the world in language that the common world will under stand, of what the law intends to do if a certain line is passed. To make the warning fair, so far as possi ble the line should be clear. Second, because of the seriousness of criminal penalties, and because crimi nal punishment usually represents the moral con demnation of the community, legislatures and not courts should define criminal activity. This policy embodies the instinctive distaste against men lan guishing in prison unless the lawmaker has clearly said they should.

Thus, where there is ambiguity in a criminal statute, doubts are resolved in favor of the defendant. Bass, U. See Pub. In relevant part, the statutes provide as follows: 18 U. Second, the defendant argues that the applica tion of the sex trafficking and forced labor statutes to BDSM activities renders the statutory language ambig uous. For the reasons stated below, the court finds both arguments to be without merit.

Applicability of the TVPA to Domestic, Intimate Relationships The defendant relies primarily on the legislative his tory of the TVPA to make the case that the charged statutes are inapplicable to intimate relationships. The court is not persuaded that the stat utory language of either statute is ambiguous such that a resort to the legislative history is appropriate and, moreover, finds that the legislative history fails to sup port the defendant's reading of the statutory language. Finally, to the extent that there are any ambiguities in the statutory language, the court finds that they are hypothetical only and inapplicable to the instant case.

According to the defendant, this phrase could be understood to encompass either all forms of work included in the dictionary definition or it could mean on ly those forms of work for which a person would ordi narily be compensated. The defendant argues that the court should limit the ambit of the statute to labor or services for which compensation is ordinarily given in order to exclude household chores performed as part of an intimate living arrangement.

As the defendant's argument implicitly acknowl edges, the plain language of the statute provides no sup port for his contention. Sullivan, F. These definitions yield scant support for the defendant's contention that the usual presence of compensation for the labor or services at issue should be a requirement for a conviction under the forced labor statute. Accordingly, the court finds no ambiguity in the statutory language. In making his claim that the court should limit the types of labor or services that fall within the statute's reach to those for which compensation is ordinarily giv en, the defendant relies primarily on the TVPA's legisla tive history. Albertini, U. Giordano, F. The court does not find the requisite extraordinary circumstances to be present here.

However, the court finds no justification for this conten tion. While the legislative history of the TVPA undoubt edly focuses primarily on the need to combat interna tional sex trafficking, the Congressional purpose and findings of the TVPA make clear the intended broad scope of the legislation. Among the Congres sional findings are the following: 3 Trafficking in persons is not limited to the sex industry. This growing transnational crime also in cludes forced labor and involves significant violations of labor, public health, and human rights standards worldwide. Traffickers lure women and girls into their networks through false promises of decent working conditions at relatively good pay as nannies, maids, dancers, factory workers, restaurant workers, sales clerks, or models.

Traffickers also buy children from poor families and sell them into prostitution or into various types of forced or bonded labor. Such force includes rape and other forms of sexual abuse, torture, starvation, imprisonment, threats, psychological abuse, and coercion. While the court observes that Congress did not expressly indicate its desire to regulate labor or services performed within the house hold, the legislative history provides no cause to believe that Congress intended that type of labor to be excluded from the legislation's reach.

Moreover, while the legislative history does not address situations where traffickers have intimate relationships with their victims, the court's survey of the TVPA's leg islative history reveals no expressed intention to pre clude criminal liability in those contexts. It did not, and we decline to introduce that additional requirement on our own. The defendant relies on United States v. Kozminski, U. See Def. Kozminski does not compel the court to adopt the defen dant's interpretation of the statute. In its findings on enacting the TVPA, Con gress observed: Involuntary servitude statutes are intended to reach cases in which persons are held in a condition of ser vitude through nonviolent coercion.

As a result, that section was interpreted to criminalize only servitude that is brought about through use or threatened use of physical or legal coercion, and to exclude other con duct that can have the same purpose and effect. Brad ley, F. Thus, in passing the TVPA, Congress made clear its intent that this statute be applied broadly in order to capture con duct that the Supreme Court had ruled beyond the reach of the statutes prohibiting involuntary servitude. Yet, the court also finds this history to be a persuasive indication that courts should be cautious about reading into this statute additional requirements not compelled by either the statute's plain language or its legislative history.

The defendant additionally points to Williams v. However, Williams is clearly distinguishable from the instant case. En mons, U. In contrast, the forced labor statute is unambiguous and the text yields no support for the de fendant's interpretation. As an example of the po tential ramifications of relying on the dictionary defini tion, the defendant explains that such an interpretation would enable a conviction under the statute if a couple jointly operated a bed and breakfast and their relation ship became abusive.

The defendant argues that, while work performed in relation to the operation of the bed and breakfast or performance of household chores could be considered labor, the statute should not be interpreted to proscribe coerced conduct of this nature. The court disagrees. Using the defendant's examples, if one spouse uses the means proscribed by the statute to coerce his spouse into performing domestic chores or tasks related to the operation of the bed and breakfast, a trier of fact would be able to find a violation of the forced labor statute.

Finally, the defendant's arguments on this claim are purely hypothetical, as the labor or services at issue in the instant case fall within the defendant's proposed definition of the terms. Based on the evidence presen ted at trial, the tasks Jodi performed at the defendant's behest are not household chores but rather labor or ser vices that would, in fact, ordinarily have been compen sated. As outlined in the court's recitation of the facts, the evidence suggests that Jodi engaged in each of these acts and that the defendant profited from displaying the fruits of her labor on the Slavespace website.

The court finds this argument nonsensical, as the statute's plain language refutes the former interpre tation. Specifically, what organizational, tactical, and issue characteristics enhance media attention? We combine detailed organizational survey data from a representative sample of local environmental organizations in North Carolina with complete news coverage of those organizations in 11 major daily newspapers in the two years following the survey 2, articles. Groups that are confrontational, volunteer-led, or advocate on behalf of novel issues do not garner as much attention in local media outlets.

These findings have important implications and challenge widely held claims about the pathways by which movement actors shape the public agenda through the news media. Camp, and Steven A. Boutcher Between and , nation-states around the world revised their criminal laws on sexual activities. This global reform wave—across countries and domains of sexual activity—followed from the reconstitution of world models of society around individuals rather than corporate bodies.

During the post-World War II period, this process rearranged the global cultural and organizational underpinnings of sex, eroding world-level support for criminal laws aimed at protecting collective entities—especially the family and the nation—and strengthening world support for laws aimed at protecting individualized persons. To make our case, we use unique cross-national and longitudinal data on the criminal regulation of rape, adultery, sodomy, and child sexual abuse. The data reveal striking counter-directional trends in sex-law reforms, which simultaneously elaborated regulations protecting individuals and dissolved laws protecting collective entities.

World-level negative-binomial regression analyses and country-level event-history analyses confirm our main propositions. The findings demonstrate a sweeping revolution in criminal-sex laws, rooted in the intensified global celebration of free-standing personhood. Turco Existing explanations of tokenism predict similar experiences for all numerically small, low-status groups. These explanations, however, cannot account for variation in the experiences of different low-status minority groups within the same setting.

This article develops a theory of tokenism that explains such variation. Drawing on interviews in the leveraged buyout industry LBO and a comparison of the differing experiences of female and African American male tokens in that setting, I argue that tokenism is contingent on the local cultural context in which it is embedded. In LBO, the industry values cultural resources that, on average, women lack but men possess, and the ideal worker is defined such that it directly conflicts with cultural beliefs about motherhood.

Consequently, in this context, gender is a more relevant status characteristic for exclusion than is race, and female tokens are differentially disadvantaged. In addition to revising received wisdom about tokenism, this study integrates and advances social psychological and cultural theories of exclusion by deepening our understanding of the role of cultural resources and schemas in occupational inequality. Putnam Although the positive association between religiosity and life satisfaction is well documented, much theoretical and empirical controversy surrounds the question of how religion actually shapes life satisfaction.

Our findings suggest that religious people are more satisfied with their lives because they regularly attend religious services and build social networks in their congregations. The effect of within-congregation friendship is contingent, however, on the presence of a strong religious identity. We find little evidence that other private or subjective aspects of religiosity affect life satisfaction independent of attendance and congregational friendship. We extend prior literature by disaggregating Asian Americans by their immigration status in relation to the U. Net of the latter variables and other demographic controls, native-born Asian American men have 8 percent lower earnings than do measurably comparable white men.

Our findings show that Asian American men who were schooled entirely overseas have substantial earnings disadvantages, while Asian American men who obtained their highest degree in the United States but completed high school overseas have an intermediate earnings disadvantage. Net of the control variables, including region of residence, only 1. Most Asian American men lag at least slightly behind white men in terms of full equality in the labor market net of the measured covariates in our statistical models. No one theoretical approach seems able to explain our findings; instead, we suggest the relevance of several perspectives, including the racialized hierarchy view, the demographic heterogeneity approach, and assimilation theory.

Zimmerman and Steven F. Messner Research consistently demonstrates that females engage in less criminal behavior than males across the life course, but research on the variability of the gender gap across contexts is sparse. To address this issue, we examine the gender gap in self-reported violent crime among adolescents across neighborhoods. Multilevel models using data from the Project of Human Development in Chicago Neighborhoods PHDCN indicate that the gender gap in violent crime decreases as levels of neighborhood disadvantage increase. Furthermore, the narrowing of the gender gap is explained by gender differences in peer influence on violent offending. Neighborhood disadvantage increases exposure to peer violence for both sexes, but peer violence has a stronger impact on violent offending for females than for males; this produces the reduction in the gender gap at higher levels of disadvantage.

We also find that the gender difference in the relationship between peer violence and offending is explained, in part, by 1 the tendency for females to have more intimate friendships than do males and 2 the moderating effect of peer intimacy on the relationship between peer violence and self-reported violent behavior. Labels: Am Sociol Rev. Friday, December 10, American Journal of Sociology 2. The Oncomouse That Roared: Hybrid Exchange Strategies as a Source of Distinction at the Boundary of Overlapping Institutions Fiona Murray Conventional wisdom suggests that when institutional logics overlap, the production of hybrids signifies collapse, blending, or easy coexistence.

The author provides an alternative interpretation: hybrids can maintain a distinctive boundary and can emerge from contestation, not coexistence. This alternative interpretation is grounded in an analysis of a critical moment at the academic-commercial boundary: the enforcement of patents to a key technology on academic geneticists. In their reaction to commercial encroachment, skilled actors scientists took the resources of the commercial logic and transformed their meaning to establish hybrid strategies that preserved the distinctive institutions. Thus, hybrids must be reconsidered as emerging from conflict and produced through boundary work to maintain the distinction and resilience of logics.

Evans How does collaboration between academic research and industry shape science? This article argues that companies' relative indifference to theory nudges their academic partners toward novel, theoretically unanticipated experiments. The article then evaluates this proposition using fieldwork, archival materials, and panel models of all academic research using the popular plant model Arabidopsis thaliana and the companies that support that research. Findings suggest that industry partnerships draw high-status academics away from confirming theories and toward speculation. For the network of scientific ideas surrounding Arabidopsis, industry sponsorship weaves discoveries around the periphery into looser, more expansive knowledge.

Government funding plays a complementary role, sponsoring focused scientific activity in dense hubs that facilitate scientific community and understanding. Three Worlds of Relief: Race, Immigration, and Public and Private Social Welfare Spending in American Cities, Cybelle Fox Using a data set of public and private relief spending for cities, this article examines the racial and ethnic patterning of social welfare provision in the United States in On the eve of the Depression, cities with more blacks or Mexicans spent the least on social assistance and relied more heavily on private money to fund their programs.

Cities with more European immigrants spent the most on relief and relied more heavily on public funding. This article unites criminology with classic work on age norms and role behavior to contend that people who persist in delinquency will be less likely to make timely adult transitions. The empirical analysis supports this proposition, with both arrest and self-reported crime blocking the passage to adult status. The authors conclude that desisting from delinquency is an important part of the package of role behaviors that define adulthood. The authors unpack racial homogeneity using a theoretical framework that distinguishes between various tie formation mechanisms and their effects on the racial composition of networks, exponential random graph modeling that can disentangle these mechanisms empirically, and a rich new data set based on the Facebook pages of a cohort of college students.

They first show that racial homogeneity results not only from racial homophily proper but also from homophily among coethnics of the same racial background and from balancing mechanisms such as the tendency to reciprocate friendships or to befriend the friends of friends, which both amplify the homogeneity effects of homophily. Then, they put the importance of racial homophily further into perspective by comparing its effects to those of other mechanisms of tie formation. Balancing, propinquity based on coresidence, and homophily regarding nonracial categories e.

Commentary and Debate Vox Regni? Labels: Am J Sociol. Blokland, Alex R. Piquero, and Gary Sweeten Much of the knowledge base on offense specialization indicates that, although there is some short-term specialization, it exists amidst much versatility in offending. Yet this general conclusion is drawn on studies using very different conceptualizations of specialization and emerges with data primarily through the first two to three decades of life. Using data on a sample of Dutch offenders through age 72 years, this article introduces and applies a new method for studying individual offender specialization over the life course.

The results indicate that although, in general, individual offending patterns over the life course are diverse, there is also evidence of an age—diversity curve. Linking offense frequency trajectories to the estimated diversity index, the authors also examine distinct specialization patterns across unique trajectory groups. Implications for theory and research are outlined. This study examined patterns of sexual victimization with and without co-occurring physical victimization and feelings of safety as reported by 6, male and female inmates. Sexual victimization often involved one to three types of sexually inappropriately behavior.

Victimization perpetrated by staff was more frequently reported by male inmates. Most inmates, independent of gender and sexual victimization, reported feeling safe inside prison. Four major findings emerge from the analysis. First, both mandatory terms and sentencing enhancements increase prison admission rates for Black and White men. Third, the effects of these policies—on both scale and disparity—are strongest and most consistent on admissions for violent offenses.

Finally, although sentencing enhancements increase admission rates more consistently than mandatory terms, mandatory terms have larger effects on admission rates for the categories—for example, violent admissions for Black men—where they do increase admission rates. The findings are consistent with theories of modern racism, which argue that, in the post-civil rights era, racial disparities are primarily produced and maintained by colorblind policies and practices. Zhang, Robert E. Roberts, and Kathryn E. McCollister Therapeutic communities have become increasingly popular among correctional agencies with drug-involved offenders. This quasi-experimental study followed a group of inmates who participated in a prison-based therapeutic community in a California state prison, with a comparison group of matched offenders, for more than 5 years after their initial prison release.

Contrary to successes reported elsewhere, this study found no difference in new arrests and returns to prison between therapeutic community participants and the comparison participants after 5 years. The average time spent in prison following initial release was about the same for both groups. Rearrest offenses were also similar in both groups. Policy implications are discussed. Hipp, Jesse Jannetta, Rita Shah, and Susan Turner This study examines the proximity of service providers to recently released parolees in California over a 2-year period The addresses of parolee residences and service providers are geocoded, and the number of various types of service providers within 2 miles 3.

Although racial and ethnic minority parolees have more service providers nearby, these providers appear to be particularly impacted based on potential demand. It is also found that the parolees arguably most in need of social services—those who have spent more time in correctional institutions, have been convicted of more serious or violent crimes in their careers, or are sex offenders—live near fewer social services, or the providers near them appear impacted.

Drury and Matt DeLisi Extant research indicates that inmates with street gang history are prone for prison misconduct but that inmates convicted of homicide offenses are less likely to be noncompliant. No research has explored the interaction between street gang history and homicide offending. Based on official infraction data from 1, inmates selected from the Southwestern United States, the current study found that inmates with street gang history and convictions for homicide offenses were significantly involved in six types of institutional misconduct, net the effects of homicide offending, offense severity, street and prison gang risk, violence history, and demographics.

Implications for theory and research are explored. Walters Prisonization as measured by number of prior incarcerations and concurrent instrumental offending as measured by contemporaneous kidnapping, rape, robbery, and burglary offenses were found to interact in multiple-homicide offenders and single-homicide offenders. Controlling for age, gender, race, criminal history, prior incarcerations, and instrumental contemporaneous offending, the interaction between prior incarceration and instrumental contemporaneous offending was a significant predictor of multiple homicide. These results constitute exploratory evidence suggesting that multiple homicide has a greater likelihood of occurring when prisonization and concurrent instrumental criminal offending are present.

The theoretical and practical implications of these findings are discussed. Labels: Crime Del. Criminology 48 4. Giordano, Robert A. Lonardo, Wendy D. Manning and Monica A. The current analysis explores connections between delinquency and the character of adolescent romantic ties, drawing primarily on the first wave of the Toledo Adolescent Relationships Study and focusing on teens with dating experience. Hipp, Joan Petersilia and Susan Turner We studied a sample of reentering parolees in California in — to examine whether the social structural context of the census tract, as well as nearby tracts, along with the relative physical closeness of social service providers affects serious recidivism resulting in imprisonment. We found that a 1 standard deviation increase in the presence of nearby social service providers within 2 miles decreases the likelihood of recidivating 41 percent and that this protective effect was particularly strong for African American parolees.

This protective effect was diminished by overtaxed services as proxied by potential demand. We found that higher concentrated disadvantage and social disorder as measured by bar and liquor store capacity in the tract increases recidivism and that higher levels of disadvantage and disorder in nearby tracts increase recidivism. A 1 standard deviation increase in the concentrated disadvantage of the focal neighborhood and the surrounding neighborhoods increases the likelihood of recidivating by 26 percent. The findings suggest that the social context to which parolees return both in their own neighborhood and in nearby neighborhoods , as well as the geographic accessibility of social service agencies, play important roles in their successful reintegration.

Johnson, Sigrid Van Wingerden and Paul Nieuwbeerta Empirical investigations of criminal sentencing represent a vast research enterprise in criminology. However, this research has been restricted almost exclusively to U. As such, an examination of more detailed international sentencing data provides an important opportunity to assess the generalizability of contemporary research and theorizing on criminal punishment in the United States.

The results indicate that offender, victim, and situational offense characteristics all exert important independent effects at sentencing and that prosecutorial recommendations exert powerful influences over judicial sentences. The article concludes with a discussion of future directions for comparative sentencing research across international contexts. Moreover, Black students consistently are disciplined more frequently and more severely than others for the same behaviors, much in the same way that Black criminals are subjected to harsher criminal punishments than other offenders.

Research has found that the racial composition of schools is partially responsible for harsher school discipline just as the racial composition of areas has been associated with punitive criminal justice measures. Yet, no research has explored comprehensively the dynamics involved in how racial threat and other factors influence discipline policies that ultimately punish Black students disproportionately. Findings indicate that schools responding to student misbehavior with one type of discipline tend to use other types of responses as well and that many factors predict the type of disciplinary response used by schools. However, disadvantaged, urban schools with a greater Black, poor, and Hispanic student population are more likely to respond to misbehavior in a punitive manner and less likely to respond in a restorative manner.

Taylor, Bradley T. Early studies focused on individual-level factors related to reporting, but recently, researchers have begun to examine neighborhood-level predictors. Most of these studies, however, omit key individual-level predictors of reporting and provide relatively little insight into the individual-level processes through which neighborhood context might affect reporting. In addition, we assess whether neighborhood characteristics influence reporting via their effect on individual-level attitudes and experiences. We find that neighborhood poverty has an inverse relationship with crime reporting intentions and that numerous individual-level measures are associated with reporting, including attitudes toward the police, delinquency, and perceptions of the community.

Taken together, our findings suggest that neighborhood context might affect reporting by shaping the attitudes and experiences of youth. Wayne Osgood, John E. Schulenberg, Jerald G. Bachman and Emily E. Messersmith Most criminological theories predict an inverse relationship between employment and crime, but teenagers' involvement in paid work during the school year is correlated positively with delinquency and substance use. Whether the work—delinquency association is causal or spurious has been debated for a long time. This study estimates the effect of paid work on juvenile delinquency using longitudinal data from the national Monitoring the Future project.

We address issues of spuriousness by using a two-level hierarchical model to estimate the relationships of within-individual changes in juvenile delinquency and substance use to those in paid work and other explanatory variables. We also disentangle the effects of actual employment from the preferences for employment to provide insight about the likely role of time-varying selection factors tied to employment, delinquency, school engagement, and leisure activities. Whereas causal effects of employment would produce differences based on whether and how many hours respondents worked, we found significantly higher rates of crime and substance use among nonemployed youth who preferred intensive versus moderate work.

Our findings suggest the relationship between high-intensity work and delinquency results from preexisting factors that lead youth to desire varying levels of employment. Ulmer, Ben Feldmeyer and Casey T. Harris Our goal in this article is to contribute conceptually and empirically to assessments of the racial invariance hypothesis, which posits that structural disadvantage predicts violent crime in the same way for all racial and ethnic groups. Conceptually, we elucidate the scope of the racial invariance hypothesis and clarify the criteria used for evaluating it. Empirically, we use — averaged arrest data from California and New York to extend analyses of the invariance hypothesis within the context of the scope and definitional issues raised in our conceptual framing—most notably by including Hispanic comparisons with Blacks and Whites, by examining the invariance assumption for homicide as well as the violent crime index, by using discrete as well as composite disadvantage measures, and by using census place localities as the study unit.

We conclude that the hypothesis should be regarded as provisional, and its scope remains to be established as to whether it applies only under narrow conditions or is a principle of general applicability. Mears and William D. Bales Although much literature has examined macrolevel employment contexts and crime rates and, at the individual level, employment and offending, few studies have examined systematically whether macrolevel employment contexts influence individual-level offending. At the same time, emerging literature on prisoner reentry increasingly underscores the potential importance of the social environment for impeding or facilitating successful transitions back into society.

All three avenues of inquiry have emphasized the salience of race-specific and offense-specific effects. This study extends prior work on ecology and offending, employment and crime, and prisoner reentry by examining the race-specific effects of unemployment rates and manufacturing employment rates on violent, property, and drug recidivism. By analyzing data on male ex-prisoners released to 67 counties in Florida, we found, as hypothesized, that Black ex-prisoners released to areas with higher Black male unemployment rates have a greater likelihood of violent recidivism.

No comparable effect was identified for White exprisoners. However, we found that White ex-prisoners, especially those without prior violent convictions, have a lower likelihood of violent recidivism when released to areas with higher White male manufacturing employment rates. We discuss the findings and their implications for theory, research, and policy. Criminology , November Volume 48, Issue 4. Labels: Criminology. Journal of Criminal Justice 38 6. General strain theory and the development of stressors and substance use over time: An empirical examination Lee Ann Slocum Little research has examined whether General Strain Theory GST can account for continuity in illicit behavior over their time.

The current study fills this void by testing the ability of GST to account for the association between adolescent and adult substance use. Four mechanisms that Agnew argues lead to behavioral continuity—a direct effect of negative emotionality and low constraint on substance use, evocative and active selection, passive selection, and stressor amplification—are examined using structural equation modeling. Drawing from the broader stress literature, an additional pathway—stress proliferation—is also tested. This research uses two unique datasets, which together provide information on the lives of high risk individuals from birth through adulthood. Support for GST explanations of continuity is mixed. The direct and moderating effects of negative emotionality and low constraint as well as the more dynamic aspects of the stress process, like proliferation and amplification, received the most empirical support.

It is argued that more attention should be directed to exploring the social processes through which stressors develop over time. General strain theory, persistence, and desistance among young adult males David Eitle Despite the surge in scholarly activity investigating the criminal career, relatively less attention has been devoted to the issue of criminal desistance versus persistence until recently. The present study contributed to our understanding of this process by exploring the suitability of General Strain Theory GST for predicting changes in criminal activity across time.

Data from a longitudinal study of males in South Florida are examined using robust regression analyses. The core GST relationship, that changes in strain should predict changes in criminal activity, was supported, even after controlling for important adult social roles such as marriage, labor force participation, and education. While no support for the proposition that changes in self-esteem and social support moderate the strain-criminal desistance association was evinced, evidence was found that angry disposition, a measure of negative emotionality, moderated the association between change in chronic stressors and change in criminal activity.

While exploratory in nature, these findings demonstrate the utility of employing GST principles in studies of criminal desistance. Sex differences in the causes of self-control: An examination of mediation, moderation, and gendered etiologies Constance L. Chapple, Jamie Vaske, Trina L. Hope Sex is one of the most robust predictors of self-control, with a consistent finding that girls score higher on a variety of measures of self-control.

In this research, we investigate three possible reasons for why this is true: first, we examine whether current predictors of self-control mediate the effect of sex on self-control, second, we examine whether sex moderates the effect of current predictors on self-control and third, we examine the possibility that the causes of self-control are gendered, necessitating different causal models for boys and girls. Using data from the Children of the National Longitudinal Survey of Youth79, we assess three, related questions: Is the sex effect on self-control mediated by current predictors of self-control? Does sex moderate the effects of current predictors of self-control?

Does the causal model predicting self-control differ for boys and girls? We find that the sex effect on self-control is robust; does not moderate the etiology of self-control; and although partially mediated by etiological variables, remains a significant predictor of self-control. Sugar and spice and everything nice? Exploring institutional misconduct among serious and violent female delinquents Ashley G. Blackburn, Chad R. Trulson Despite an emerging body of research on the institutional behavior and adjustment of delinquent males, there exists little information on the incarceration experiences of female delinquents. The present study explored the incidence, prevalence, and determinants of institutional misconduct among a sample of serious and violent delinquent females sentenced to state juvenile incarceration.

Secondary data analysis was used for the present study. Data utilized were derived from information originally gathered by correctional staff during intake at a state Youth Correctional System a pseudonym and during an offender's entire incarceration through on-site diagnostic processes, staff observations, official records, and offender self-reports. Members of the study sample engaged in roughly incidents of major misconduct and more than 12, instances of minor institutional misconduct during their incarceration. Results from negative binomial regression models examining four different types of institutional misconduct revealed that age at commitment, offense type, mental health status, and gang affiliation were related to the expected rate of misconduct, although this varied by misconduct type.

Institutionalization is not necessarily a period of desistance from offending for all delinquent girls. As institutional misconduct may impact post-release recidivism, it is important to identify and intervene with at-risk juveniles during periods of incarceration. The influence of forensic evidence on the case outcomes of homicide incidents Deborah Baskin, Ira Sommers In spite of the growth of forensic science services little published research exists related to the impact of forensic evidence on criminal case outcomes.

The present study focused on the influence of forensic evidence on the case processing of homicide incidents. The study utilized a prospective analysis of official record data that followed homicide cases in five jurisdictions from the time of police incident report to final criminal disposition. The results showed that most homicides went unsolved Only Cases were more likely to have arrests, referrals, and charges when witnesses provided information to the police.

Suspects who knew their victims were more likely to be arrested and referred to the district attorney. Homicides committed with firearms were less likely to be cleared. The most noteworthy finding was that none of the forensic evidence variables significantly influenced criminal justice outcomes. The study results suggest that forensic evidence is auxiliary and non-determinative for homicide cases. Healthy, wealthy, and wise: Incorporating health issues as a source of strain in Agnew's general strain theory John Stogner, Chris L.

Gibson The current study uses Agnew's general strain theory GST as a foundation to argue that poor health may lead to delinquency. Those who suffer frequently from minor health problems and lack resources to afford proper medical care are expected to experience elevated levels of health-related strain, negative emotional affect, and report engaging in more delinquent acts. Using longitudinal data from the National Longitudinal Study of Adolescent Health Add Health , negative binomial regression models were estimated and show that health strains increase the subsequent frequency of non-violent delinquency even when controlling for important demographic and theoretically derived variables. Health strain's influence on non-violent delinquency was not conditioned by anger, depression, self-esteem, low constraint, or religiosity.

Implications for GST are discussed and a modest research agenda for investigating health strain is identified. Cleaning up your act: Forensic awareness as a detection avoidance strategy Eric Beauregard, Martin Bouchard Although rational choice researchers has investigated how offenders successfully commit certain crimes, there is a lack of research looking at the factors explaining the use — or not - of certain detection avoidance strategies.

Factors influencing forensic awareness are tested using logistic regression models on a sample of rape events collected from offenders incarcerated in Canada. However, offenders who show some form of target selection are more likely to take forensic precautions. Finally, offenders who break and enter in the victim's residence, and undertake specific sexual acts during the crime are also more likely to exhibit forensic awareness.

Despite the increasing use and knowledge of forensic evidence by law enforcement, offenders are inconsistent in their forensic awareness and they direct most of their efforts toward protecting their identity, neglecting to either destroy or clean up DNA that could be recovered at the crime scene. Moreover, this study investigated whether gender moderated the association between shift work and stress, sleep and health.

Additional analyses were performed to find out how stress and shift work interact in explaining sleep and health. The findings are based on a cross-sectional survey. A written questionnaire was sent to all employees of a local police force. Shift work was associated with increased social stress, work discontent and sleep complaints. In turn, shift workers reported decreased use of primary health care. Moreover, stress was associated with increased sleep complaints and lower scores in perceived health. The interplay between stress and shift work did not produce any significant effects. Workforce health promotion should make attempts to reduce chronic stress, while occupational health physicians should emphasize the diagnosis of undetected sleep disorders.

An empirical examination of adolescence-limited offending: A direct test of Moffitt's maturity gap thesis J. Barnes, Kevin M. Beaver Provide the first direct test of Moffitt's hypothesis linking the maturity gap with adolescent delinquency. Data were drawn from the National Longitudinal Study of Adolescent Health Add Health and a direct measure of the maturity gap was constructed. Negative binomial regression models—survey-corrected to account for the Add Health research design—were estimated.

Consistent with Moffitt's theory, the results of the analyses revealed that the maturity gap was predictive of minor forms of delinquency and drug use but not of more serious types of offending behaviors for males. Findings were less supportive of Moffitt's hypothesis for females. Moffitt's maturity gap thesis is a viable explanation of adolescent delinquency, especially for males. This portion of the theory, which has largely gone unexamined, warrants further inquiry from criminologists. Research Note: Assessing the validity of college samples: Are students really that different?

Filip M. Wiecko The purpose of this research note is to explore the validity of college student samples for criminology and criminal justice research. Some scholars have suggested that college populations are comprised of individuals who are different from the rest of society and that the use of college students for social research may distort our theoretical understanding of crime and criminality. The results indicate that there is almost no statistically significant difference in behaviors and only minor differences in the frequency of behaviors and attitudes.

The findings from this investigation suggest that while college students may be culturally unique, this uniqueness does not seem to affect validity. Assessing the victim-offender overlap among Puerto Rican youth Mildred M. Maldonado-Molina, Wesley G. Jennings, Amy L.

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