The Failure of the Criminal Justice System on Protecting Minority Women

By: Michelle Miles

The current criminal justice system does not account for the psychological injuries that stem from surviving a rape. This article focuses on female/women rape victims who have dealt with suicidal ideation. Rape is a severe crime, defined as “the penetration, no matter how slight, of the vagina or anus with any body part or object, or oral penetration by a sex organ of another person, without the consent of the victim.”[i] It impacts the individual, not only physically but also mentally, emotionally, and spiritually. Rape is known to be the most under-reported violent crime in the United States.[ii]

There are too many reasons for this disheartening fact which this article cannot fully cover in its entirety. One significant, failing aspect of the United States Criminal Justice System is the mistrust between rape victims and the justice system. First, the article will discuss why there is such mistrust between these two groups, which leads to systemic under-reporting. Second, due to the prevailing factor, a correlation between rape and suicidal ideation exists and will be reviewed as the majority of sexual assaults are not reported. Third, addressing the need for legislation that introduces the critical need for after-care therapy funded by the government is an integral factor in reducing suicide. Lastly, the emerging awareness of the criminal justice system’s failure to protect the community includes rape victims. The failure to provide justice will only end with more rape victims not reporting the crime and the suicide rates spiking rapidly.

The Epidemic of Distrust Between Rape Victims and the Criminal Justice System

The initial experience of rape can be traumatizing for any individual. The last thing a victim should worry about is if the justice system will believe them. The “prevalence [of sexual assault] is between 2% and 10%,” in the United States; therefore, it should be taken seriously when reported. The automatic distrust toward the victim turns the process of justice into a circus of roadblocks with the objective of dismantling the victim’s claim. Unfortunately, many females encounter the described experience after having the courage to come forth and report a heinous crime that will forever follow them. The system has a duty to protect victims the moment they explain the circumstances of the crime committed. There should not be any lack of protection or cooperation toward any rape victim, including first-hand support and assistance from police officers to prosecutors. If there was overwhelming and mandatory support to fight justice, which every rape victim deserves­­­­­, the mistrust would not exist. In return, cases of rape could be solved more diligently and justly from the beginning. The path of recovery would not end in the suicidal ideation that most confront, nor the ultimate suicide attempt that too often follows if the justice system provided professional help at the outset.

Mistrust is the core problem connecting all the negative projections between rape victims and the criminal justice system. According to the U.S. Department of Justice, “In 2005-[20]10, females who were age 34 or younger, who lived in lower income households, and who lived in rural areas had some of the highest rates of sexual violence.” [iii] Many low-income neighborhoods are considered breeding grounds for crime because the police have a broken relationship with residents, especially among minorities. There is a stigma within minority communities that leads to police interaction as a sign against the community, as manifested throughout the history of oppression, discrimination, and inequality. The response police give toward low-income neighborhoods often normalizes crimes such as robbery, assault, and even murder in certain cities. Residents in these communities are afraid to speak with the police, as the repercussions are rampant because of the built-up mistrust between police and minorities. The police lack the sensitivity and special training they need to work successfully on the cases in a rightfully cautious community.

The National Sexual Violence Resource Center (NSVRC) found that “63% of sexual assaults are not reported to police.”[iv] This statistic vividly shows the apparent mistrust between the police and community that translates to the relationship, or lack thereof, between rape victims and the criminal justice system in the United States. As a society, we need to question why the mistrust between the community and the police hampers the just and prosperous treatment rape victims deserve. The answer might seem ambiguous. The history of oppression in America has not always been trustworthy or fair for many minorities. This has resulted in mass incarceration for many nonviolent crimes, often including wrongly convicted individuals for crimes they did not commit. For many minorities, the likely consequences resulting from interacting with the police would far outweigh any potential benefits. If justice in society is not the main objective for the police, then rape victims will remain hesitant to report this severe and violent crime when they know lesser crimes are not taken seriously enough either.

There are many reasons why survivors do not come forward in reporting the crime.

“Twenty percent [of these victims], according to the D.O.J. [Department of Justice] report, worry about retaliation — not just from the perpetrator, but from society at large. Thirteen percent say they think the police would not do anything to help. Tragically, eight percent said they did not think the rape or sexual assault was important enough to report”[v].

These statistics show a concerning pattern that the crime itself has an underlining stigma making victims even more reluctant to report. Many survivors have a “fear of revictimization, distortion of allegations, and generally not being believed.”[vi] These feelings or emotions should not exist or surround victims when they just want justice. There is no question that safety is an issue when deciding to come forth. Victims, therefore, do not trust the police to protect them, and, as a result, the crime of rape is becoming a norm within American society.

“While 80% of reported rapes are against white women, minorities are more likely to be assaulted. Rates of rape [are]:

• White-17.7%;
• Black: 18.8%;
• Asian/Pacific Islander-6.8%;
• American Indian/Alaskan Women-34.1%;
• Mixed Race-24.4%.

The stats for non-whites are probably low, since barriers to reporting would be increased for women of color.”[vii] These statistics demonstrate the dire truth that minority women are at higher risk of being raped compared to non-minority women. The history of oppression has had a significant role in the current state of many minority women being more vulnerable because of more conducive surroundings for the crime to occur and the notion that police do not care enough when called. The police either do not show up in a timely manner in certain neighborhoods or when they do, excuses for the perpetrator’s behavior are given. This results in a learned silence that travels to younger generations, thereby perpetuating the non-reporting of this crime.

Minimum Legislation

In the 106^th United States Congress, The Federal Victims’ Rights Amendment (V.R.A.) was a start toward protecting crime victims in court, but both the House and Senate has so far failed to pass it, in yet another defeat for those who support the efforts to protect victims of rape. The Amendment is not perfect but a much-needed beginning. The American Civil Liberties Union states that the V.R.A.:

“[P]roposed ‘rights’ include notification of, guaranteed admission to and the right to speak during the course of legal proceedings, including: pre-trial release, plea bargains, sentencing and parole.  Additionally, the V.R.A. requires courts to consider victims’ interests to ensure trials occurs without ‘unreasonable delays’ and to consider the victims’ safety when defendants are considered for conditional releases.”[viii]

The criminal justice system itself has failed to give women of our society the necessary and much deserved attention by not continuing the fight for justice.

A more permanent pathway for protecting rape victims would be to pass the V.R.A. as a constitutional amendment and for states to ratify the V.R.A. instead of allowing states to choose the rights that rape victims deserve. The balance of state and federal government would be impacted, but a vital shift in balance of power to protect the women in our country is proper and necessary. In 2004, Section 3771 of Title 18 of the United States Code  was “enacted as part of the Justice for All Act of 2004, [to] establish the rights of crime victims in federal criminal justice proceedings, provides mechanisms for victims to enforce those rights, and gives victims and prosecutors standing to assert victims’ rights”[ix]

Guaranteeing that the CVRA is adopted as an amendment to the U.S. Constitution will in return lay out a standard for state constitutions to adopt as well. The rights maintained in the CVRA are core strides for court proceedings that majorly impact rape victims seeking justice, but it does not address the emotional, physical and mental trauma that needs to be approached in a legal sense. The missing component of after-care counseling should create legislation guaranteed by the Constitution that will uphold stronger rights for rape victims. Providing mandatory and necessary therapy as part of case management will help eliminate the suicidal crisis of our women discussed further below.

Current Atmosphere Society Ignores

The media continues to pour out and disseminate example after example where the victim is disbelieved–Anita Hill, Dr. Christine Ford– or light sentences are given to such a serious offense, – People v. Turner – when such incidents happen to everyday women but kept silent and untold. In State v. Holtzclaw, the defendant, a police officer with a duty to protect and serve the community, took advantage of vulnerable women “who fit a profile of members of our society who are confronted rightly or wrongly by police all the time.”[x]  The prosecutor said that the victims were targeted because they were low-income African American women with criminal records and “whose credibility would be questioned by both law enforcement and society in general.”[xi]

The case exemplifies the struggle that many women, especially minority women, face when they consider reporting knowing their credibility will be likely and unfairly. Sadly, numbers paint the picture in living color. Studies show a dramatic decrease in “reporting to police from 2017 to 2018. Forty-percent (40%) of rapes and sexual assaults were reported to police in 2017, but only about 25% were reported to police in 2018.”[xii] The reason for the statistic has not been explained, but a mere correlation of mistrust with the police due to police brutality could be an explanation for the underreporting to the police in 2018 as police are seen as a outright threat.

The current message the criminal justice system is sending to all women in the United States is that enforcing rape laws and prosecuting offenders is not a priority of the current justice system. The effect of such a message can leave victims feeling as if there is no one to blame, but herself. “As psychotherapist Beverly Engel puts it, “victims are often too ashamed to come forward. Sexual assault is a very humiliating and dehumanizing act against someone.” Why do victims often blame themselves? Engel continues: “[A]ttached to that shame is a lot of self-blame [. . .] because in our culture, we tend to blame victims in general.”[xiii] The blame that halts reporting must never be an aspect a victim of rape should endure. Unfortunately, all too often this blame can turn into depression, followed by suicidal ideation, and then suicide. Providing victims with counseling as part of case management can save lives.

The Correlation Between Rape Victims and Suicidal Ideation

Many people might not suspect that there is a correlation between rape victims and suicidal ideation, because the root of the problem has never been uncovered. The crime of rape has been severely stigmatized as humiliating because of the excuses afforded to the perpetrators who commit such a dehumanizing crime. The effects of being raped can be tremendous and affect various aspects of a woman’s life. The act itself can break the future of many especially if they feel no one cares enough to lend a hand. The consequences that society forces upon victims of rape stems from the attitudes and behavior within the criminal justice system.

It is “estimated that 734,630 people were raped (threatened, attempted, or completed) in the United States in 2018”[xiv] “In 2005-10, about 80% of female rape or sexual assault victims treated for injuries received care in a hospital, doctor’s office, or emergency room, compared to 65% in 1994-98”[xv] while “58% of female victims of sexual violence suffered a physical injury during the victimization, such as cuts, bruises, internal injuries, broken bones, gunshot wounds, or rape injuries.”[xvi] The reality that many women experience this disturbing aftermath is only the surface of pain they endure. The unreported reality is that many women go through this aftermath alone and scared, with lifelong post-traumatic stress disorder (PTSD) or rape-related PTSD (RR-PTSD) which can include symptoms that can turn into suicidal thoughts leading to suicide from the untreated trauma.

Suicidal ideation can be defined in two ways; 1) passive suicidal ideation “occurs when you wish you were dead or that you could die, but you don’t actually have any plans to commit suicide”[xvii] or  2) active suicidal ideation “is not only thinking about it but having the intent to commit suicide, including planning how to do it.” [xviii] One major reason why many women do not believe they can recover from their unfortunate and undeserving rape is because there is no consistent and trusting justice system that will prevent them from being raped again. The safety and comfort in one’s surroundings have vanished, especially if the rapist is someone close to family or is an actual relative. The main trait that many rapists share is the distinct ability to create a trustful bond that breaks after being taken advantage of. The organization, Rainn, states that “33% [of rapes in 8 out of 10] are committed by a current or former spouse, boyfriend or girlfriend” and “34% [of rapes with juvenile victims] were [by] family members.” [xix] There is no wonder why many victims feel betrayed and scared when the people they trust break that sacred b0nd and then no criminal justice system will protect them from unsaid danger. This does not devalue the committed rapes by strangers or acquaintances. It only shrinks the safety net as every person walking by is now an unknown threat of sexual violence. It amplifies the thoughts of suicidal ideation when there seems as if nobodies left to trust or feel vulnerable with and nowhere left to turn for help or sanctuary.

“A majority of female victims of completed or attempted rape first experienced such victimization early in life, with 81.3% (nearly 20.8 million victims) reporting that it first occurred prior to age 25.”[xx] The early struggle that many females face is not to be taken as just another statistic, but as the deadly truth that having been raped increases the likelihood of suffering a major depressive episode due to sexual assault trauma by three times.[xxi] A major depressive episode or even minor depression can fester into suicidal ideation, more specifically passive suicidal ideation at first.  In a national study of female participants:

• “(33%) of rape survivors said they had contemplated suicide.
• Those who had been raped were 4.1 times more likely than non-crime victims to have contemplated suicide.
• Those who had been raped were 13 times more likely than non-crime victims to have attempted suicide (13% vs. 1%).”[xxii]

These statistics cry out that women who experience rape are more prone to suicidal ideation that can develop into a suicide attempt. The traumatic experience can show high levels of RR-PTSD (approx. 211,000 women annually)[xxiii] as mentioned earlier when sexual victimization occurs. Most rape victims battle with risk factors known to increase the risk of negative outcomes such as suicide.[xxiv] Common risk factors include but are not limited to: depression, shame, substance abuse, eating disorders, psychological distress, hopelessness, social isolation, perfectionism, burdensome etc.[xxv] Various risk factors develop typically after women suffer this trauma. Offering immediate and appropriate after-care can prevent such mental and emotional suffering including suicide ideation and suicide itself.

The risk factors can be outweighed by protective factors such as but not limited to: coping skills, belief system, supportive environment, safe space, peer support and adequate mental health care etc.[xxvi] These protective factors are can be learned and applied to replace the risk factors through provided after-care treatment. The changing aspect or life-saving aspect could be providing various counseling that should be included in case management implemented by every state government.

Rape victims will most likely not be survivors of rape without the help of mental health providers. “Life, Liberty, and the Pursuit of Happiness”[xxvii] are fundamental rights which our government is created to protect, and which belong to every individual including rape victims. The correlation between rape and suicidal ideation cannot be ignored any longer. The criminal justice has to break the dangerous cycle of underreporting by listening to the key concerns of the minority communities where rapes are becoming a norm. A norm that is affecting the lives of our women because of the mistrust with the police. Carrying out that task is the first step in protecting rape victims in seeking rightful justice in every case. Showcasing serious consequences with justifiable sentences brought by honorable prosecutors will lead to more trust and belief in the system that has a history of turning a blind eye. The next step entails enforcing after-care counseling as part of mandatory case management to treat and dissolve any likely risk factors before they evolve into suicidal ideation.

No more lives need to be lost due to untreated trauma. It should be the duty of the criminal justice system to identify the critical concerns of rape victims and determine the best course of action instead of blatantly neglecting the crisis. Minority women already experience the system’s rejection and minimization of them and their trauma, with more and more of them eventually ending their lives by suicides. It doesn’t have to be this way.

Aftermath of Sexual Crimes

In Police Sexual Violence: Police Brutality, #MeToo, and Masculinities, Dara E. Purvis and Melissa Blanco state that “[i]n general, sexual crimes have a high recidivism rate.165 For example, one study found that in the general population (not solely police officers), offenders who were not caught and prosecuted averaged more than five rapes.”[xxviii] (1510) Recidivism is defined as “a person’s tendency to relapse into a previous condition or mode of behavior, especially a relapse into criminal behavior.”[xxix] The above study expresses the failure of the criminal justice system in protecting rape victims by having a high recidivism rate for sexual crimes and result of offenders not being caught. Most people would understand the fear of repeated behavior that is hurtful, so why does the criminal justice system ignore the apparent crisis of society’s most vulnerable women?

The problem that these women face every day should not be taken lightly or swept under the rug until it happens to you or someone you love. It should matter before the person you love commits suicide; it should matter before the moment suicidal ideation enters the conscience of the victim. Ideally people should care for one another and support one another with care and kindness from the beginning. If rape victims felt that atmosphere surrounding them then there might be an option to communicate their internal struggles more openly if met with empathy and sympathy. The support system is an indispensable element in recovering from any hardship, but especially a hardship that rape victims had no fault in.

Society must learn to not persecute rape victims by blaming them for actions not in their control. Rape is a serious crime, whether a victim comes forth when it happened or later in life should not defeat the seriousness of the situation. (Another reason why the criminal justice system needs to change is to encourage victims to come forth to assure prosecution before the various state’s statute of limitations expires.) Pin-pointing the blame on the victims is unlawful and the criminal justice system should instead defend the victims and seriously prosecute the offenders.

The attitude of society has become callous and selfish to the point where no one cares about one another unless there is a mutual benefit involved. The honest truth is not meant to deter people, but instead open the mind of our dreary lives and create an environment that allows not only rape victims to come forth but all victims of sexual assault. Sympathy, support, trust, and kindness can help change the willingness of rape victims to report and in return can help the court system understand the overwhelming need for criminal justice reform on both state and federal level.

It would be a mistake to state that the crime of rape will be eradicated from society, as man has no control over the actions of another. Fortunately, the legal system can impede such a crime by prosecuting beyond any reasonable doubt and distinctively define the consequence of lack of consent from a woman. Rebuilding the trust between police and society, especially minority women can be a stepping-stone for the criminal justice system. The assumption that our minority women do not deserve protection will not continue in any step throughout law enforcement and the criminal justice system.

Awareness Toward Society

There should be a mandatory standard that protects rape victims, which is set by Congress, that implements all states to adhere under the Fourteenth Amendment. “Recognizing that sexual assault violates a right to bodily integrity … [and] [s]exual assault [is seen] as a violation of a protected constitutional right [under 18 U.S.C. § 242]. [xxx] Rape victims deserve equal protection of the laws under §5 of the Fourteenth Amendment[xxxi], as any woman can become a victim of rape and any rape has the possibility of turning into murder or, as evidenced, suicide if action is not undertaken in a timely manner.

The beginning of awareness starts at the root of the problem. The police department needs to be reformed as an aspect to the criminal justice system. The police officers are supposed to be the first ones on the scene of a reported rape, but, as mentioned above, are not even called anymore due to the mistrust leading to underreporting. As a retired police officer in Alabama paraphrased; there needs to be more academy training that teaches police officers on how to deal with serious sexual crimes and violent sexual crimes, and more implementation on preventing minority bias and stereotypes when interacting with sexual assault victims as the lack of this training is evident and damaging.

Many States like North Carolina have victim services such as:

• Victim Compensation (reimburses victims medical expenses/lost wages);
• Rape Victim Assistance (cost of a forensic medical examination);
• Statewide Victim Assistance (criminal justice information sharing system that sends information regarding the victim’s offender); and
• Victim Services for Prisons, Probation and Parole (provides victims with a safety plan that also regards safety concerns about the offender). [xxxii]

There are two distinct problems that need to be addressed for the betterment of rape victim treatment to deter suicidal ideation. The federal government should make it mandatory for all states to require these above victim services and allow free therapy. It should come as a disappointment that after-care therapy is not seen as an essential rape victim service. The key to stop the crisis of rape victims committing suicide is to establish a necessary therapy victim service with accredited therapists provided by every state/territory in the United States.

Currently, there are “approximately 2,000 organizations … established to provide support and services to rape victims,”[xxxiii] These organizations are generally non-profits who work relentlessly to help their local communities with the help of a vast majority of volunteers. Many independent sexual assault providers work with the National Sexual Assault Hotline, but oftentimes still lack the necessary funds from their respective states. The confidential service of training volunteers on crisis intervention especially with suicidal individuals or advocating for rape victims throughout the process of a rape kit exam to therapy takes time and costs money. The positive results these programs have in affecting the lives of victims should justify the allocation of more resources stemming from their government.

Every organization that treats victims of sexual assault carries the responsibility of caring for these women and should be supported by their state with satisfactory funds from the federal government. Ensuring that women who unfortunately experience rape are sought after from the moment they call the police.

Conclusion

Recognize that “1 out of every 6 American women has been the victim of an attempted or completed rape in her lifetime.”[xxxiv] Women in our society deserve and demand a better criminal justice system that cares and fights for their purposeful lives. There is a major problem concerning rape victims and the somber truth on how their lives have been reduced to suicidal ideation that in turn results in a high probability of suicide. Awareness is a start, but the suicidal crisis should not end with only awareness, rather with proposed changes that reverse the misguided black hole solution of suicide.

The crime of rape characterized by underreporting will not stop, and if we as individuals do not start to realize the seriousness survivors of rape endure, then we will diminish their hopeful recovery. The continuing mistrust needs to be addressed between police and minority communities. These changes will lead to more reporting of rape that might seem overwhelming but will lead to cases that prosecutors can seek justice for. The criminal justice system needs to reform their victim services to include after-care treatment to reduce the suicidal rate that can be prevented with proper counseling. If action is not implemented now, more women will die due to society’s ignorance and the justice system’s negligence and incompetence to care and save their lives.

 

Citations

[i] U.S. Department of Justice Archives, AN UPDATED DEFININTION OF RAPE (Jan. 6, 2012), https://www.justice.gov/archives/opa/blog/updated-definition-rape

[ii] National Sexual Violence Resource Center: Info & Stats for Journalists, Statistics about Sexual Violence, https://www.nsvrc.org/sites/default/files/publications_nsvrc_factsheet_media-packet_statistics-about-sexual-violence_0.pdf (last visited Feb. 21, 2020).

[iii] U.S. Department of Justice, Bureau of Justice Statistics, Female Victims of Sexual Violence, 1994-2010 (March 2013), https://www.bjs.gov/content/pub/pdf/fvsv9410.pdf

[iv] NATIONAL SEXUAL VIOLOENCE RESOURCE CENTER: INFO & STATS FOR JOURNALISTS, STATISTICS ABOUT SEXUAL VIOLENCE, supra note 2 at J.

[v] Cameron Kimble, Sexual Assault Remains Dramatically Underreported, BRENNAN CENTER FOR JUSTICE (Oct. 4, 2018), https://www.brennancenter.org/our-work/analysis-opinion/sexual-assault-remains-dramatically-underreported

[vi] Id.

[vii] North Coast Rape Crisis Team, Sexualized Violence Statistics, https://stoprape.humboldt.edu/statistics (last visited Feb. 21, 2021)

[viii] American Civil Liberties Union (ACLU), Proposed Victim’s Rights Amendment, https://www.aclu.org/other/aclu-fact-sheet-proposed-victims-rights-amendment#:~:text=Thirty%2Dtwo%20states%20already%20have,the%20VRA%20has%20been%20proposed.&text=Each%20time%2C%20the%20amendment%20failed,or%20the%20Senate%20to%20pass. (last visited Feb 20, 2021)

[ix] Office of Justice Programs, About Victims’ Rights, VictimLaw.org, https://www.victimlaw.org/victimlaw/pages/victimsRight.jsp(last visited Feb. 21, 2021)

[x] Matt Ford, A Guilty Verdict for Daniel Holtzclaw, The Atlantic: POLITICS (December 11, 2015), https://www.theatlantic.com/politics/archive/2015/12/daniel-holtzclaw-trial-guilty/420009/

[xi] Id.

[xii] Morgan, R., & Oudekerk, B. (2019). Criminal victimization, 2018 (NCJ 253043). U.S. Department of Justice, Bureau of Justice Statistics. https://www.bjs.gov/content/pub/pdf/cv18.pdf

[xiii]  Kimble, supra note 6.

[xiv] Morgan, R., & Oudekerk, B, supra note 12.

[xv] U.S. Department of Justice, Female Victims of Sexual Violence, 1994-2010, Bureau of Justice Statistics (March 2013), supra note 4 at 6.

[xvi] Id.

[xvii] Marcia Purse, What is Suicidal Ideation? A Look at Dangerous Thought Patterns, Verywell Mind (March 25, 2020), https://www.verywellmind.com/suicidal-ideation-380609

[xviii] Id.

[xix] Perpetrators of Sexual Violence: Statistics, RAINN https://rainn.org/statistics/perpetrators-sexual-violence?_ga=2.196308588.1729008576.1610302877-1176470779.1608138990 (last visited Feb. 21, 2021)

[xx] NISVS 2015 Summary Report-Sexual Violence by any Perpetrator, National Sexual Violence Resource Center, https://www.nsvrc.org/statistics#:~:text=The%20self%2Dreported%20incidence%20of,the%20United%20States%20in%202018. (last visited Feb. 21, 2021)

[xxi] Networks for LIFE, Identifying and Preventing Suicide in Post-Sexual Assault Care, Youth Suicide Prevention Program, https://www.wcsap.org/sites/default/files/uploads/webinars/Suicide_Intervention_Recording/Networks_for_Life_for_Sexual_Assault_Care.pdf(last visited Feb. 21, 2021)

[xxii] Id.

[xxiii] Dean G. Kilpatrick, Ph.D., The Mental Health Impact of Rape, National Violence Against Women Prevention Research Center, https://mainweb-v.musc.edu/vawprevention/research/mentalimpact.shtml

[xxiv] Networks for LIFE, Identifying and Preventing Suicide in Post-Sexual Assault Care, Youth Suicide Prevention Program, supranote 21.

[xxv] Id.

[xxvi] Id.

[xxvii] Declaration of Indep.

[xxviii] Dara E. Purvis & Melissa Blanco, Police Sexual Violence: Police Brutality, #MeToo, and Masculinities, (2020) Cal L. Rev., https://www.californialawreview.org/wp-content/uploads/2020/11/3-Purvis-Blanco-FINAL.pdf

[xxix] What is Recidivism? RED, https://stoprecidivism.org/what-is-recidivism/ (last visited Feb. 20, 2021)

[xxx] Andrew J. Simons, Being Secure in One’s Person: Does Sexual Assault Violate a Constitutionally Protected Right?, B.C. L. Rev.,(Nov. 1, 1997)

[xxxi] U.S. CONST. Amend. XIV, § 5

[xxxii] Victim Services, NC Department of Public Safety, (2020) https://www.ncdps.gov/dps-services/victim-services

[xxxiii] Chapter 9 Sexual Assault, VC Archive, https://www.ncjrs.gov/ovc_archives/nvaa99/chap9.htm (last visited Feb. 21, 2021)

[xxxiv] Scope of the Problem: Statistics, RAINN, https://www.rainn.org/statistics/scope-problem (last visited Feb. 21, 2021)