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University of Technology Sydney Law Research Series |
Last Updated: 21 April 2017
Linda Steele, ‘Policing Normalcy: Sexual Violence Against Women Offenders with Disability’ (2017) 31(3) Continuum 422-435 (435 (DOI: 10.1177/1462474516680204; appeared in special issue: ‘Normalcy and Disability: Intersections Among Norms, Law, and Culture’)
Policing Normalcy: Sexual Violence Against Women Offenders with Disability
Linda Steele
University of Wollongong, Wollongong, NSW, Australia
Room 67.206A, School of Law, University of Wollongong, Wollongong, NSW 2522 Australia. +61 2 4221 3695
lsteele@uow.edu.au
This work was supported by the University of Wollongong Legal Intersections Research Centre under a Small Research Grant; and an Endeavour Foundation Endowment Challenge Fund Student Grant.
Acknowledgements
Thank you to Olivia Todhunter and Julian Trofimovs for their research assistance. Thank you to the feedback received on earlier drafts from Eileen Baldry, Felicity Bell and Leanne Dowse. Thank you to feedback on related papers received at the Feminist Research Network Works in Progress event and at ‘Complicities’ Law, Literature and the Humanities Association of Australasia Conference.
Disclosure statement
No potential conflict of interest was reported by the
author.
Notes on contributor
Linda Steele is currently a lecturer in the
School of Law and a member of Legal Intersections Research Centre, University of
Wollongong. Linda’s
research explores the intersections of disability, law
and injustice. Recent publications include: “Court-Authorised
Sterilisation
and Human Rights: Inequality, Discrimination and Violence Against
Women and Girls with Disability?” 2016. UNSW Law Journal 39 (3):
1002–1037 and “Gender, Disability Rights and Violence Against
Medical Bodies.” Australian Feminist Studies. 2016. 31 (88):
117–124. DOI: 10.1080/08164649.2016.1224081.
Policing Normalcy: Sexual Violence Against Women Offenders with Disability
This article explores police responses to sexual violence reported by women offenders designated as having cognitive and psychosocial disabilities. The article does so by reference to the critical disability studies analytical approach to disability as socially constructed ‘abnormality’. This article utilises this approach in analysing the recorded police contacts of one woman offender designated as disabled, ‘Jane’. Jane has had multiple contacts with police over a period of 15 years as a victim of sexual violence, alleged offender and ‘mentally ill’ person. The article finds that through multiple contacts with police as victim, alleged offender and ‘mentally ill’ person the police events records build a narrative of Jane as an ‘abnormal’ body who is reduced to a drain on police and public health resources, a dishonest and nuisance offender and an attention seeker. The article argues that it is the interlocking discourses of gender, disability and criminality that produce Jane as unworthy of victim status and, perversely, in need of punishment by the criminal justice system for her public displays of trauma, mental distress and requests for police assistance. Ultimately, the article concludes that we need to give greater attention to the relationship between disability and affect in understanding police responses to violence against women offenders designated as disabled and in contesting these women’s status as ‘ungrievable’ victims of violence.
Keywords: disability, normalcy, violence, law, police, critical disability studies
Women designated as having cognitive and psychosocial disabilities (‘women designated as disabled’) experience disproportionate rates of violence (particularly sexual violence) when compared to women and men not designated as disabled, and women and men designated with other disabilities (Frohmader and Sands 2015, 38; see also Dowse et al. 2016) Women designated as disabled also have poor justice outcomes when seeking legal redress in relation to their experiences of violence, with high attrition of complaints at various points throughout the criminal justice process. The failure of police to exercise their discretion to investigate complaints and press charges is a particularly significant issue, with stereotypes about gender and disability being commonly identified as key causes (Frohmader and Sands 2015, 19, 55–57). Thus, women designated as disabled experience significant difficulties in relation to acts of violence themselves and the affective and legal responses to these acts of violence.
In her groundbreaking scholarship on intersectionality, Kimberle Crenshaw emphasised that violence against women is not only shaped by gender but other dimensions of identity (Crenshaw 1991, 1242, see further 1269–1271; for a recent discussion of intersectionality which explicitly includes ability see Collins and Bilge 2016). Building on this, scholars and advocates argue that the incidence of violence and the justice outcomes for women designated as disabled must be understood at the intersection of gender and disability. For example, Stephanie Ortoleva and Hope Lewis state ‘when gender and disability intersect, violence takes on unique forms, has unique causes, and results in unique consequences’ (2012, 14; see also Frohmader and Sands 2015, 17–18). Scholars and advocates argue that the complaints of women with cognitive and psychosocial disabilities about sexual violence are routinely dismissed by police by reason of their perceptions of the women at the intersection of gender and disability. Such perceptions relate to these women being oversexualised (invite sexual violence) or undersexed (incapable of engaging in sexual activity), irrational (cannot be trusted or believed) and incapable (cannot comprehend sex or violence) (for scholarly work see, eg Dowse, Frohmader, and Meekosha 2010, 249, 265–266; Ellison 2015; Ellison et al. 2015a, 2015b; Keilty and Connelly 2001; Murray and Heenan 2012; Murray and Powell 2008; Razack 1995; for advocacy work see, eg, Dowse et al. 2013; Frohmader and Sands 2015; Ortoleva and Lewis 2012; Pettitt et al. 2013).
Scholars and advocates have paid less attention to differentials between groups of women designated as disabled along other axes of marginalisation (see, however, Baldry, Dowse and Clarence 2012; Baldry et al. 2015, 39, 130–135; Frohmader and Sands 2015; Ortoleva and Lewis 2012). Attention to these differentials is important because, as Sherene Razack argues in the context of analysing cases of sexual assault of women with developmental disabilities, there needs to be ‘a clear articulation of how power relations produce the responses of nondisabled individuals to persons with disabilities and how the subtexts of race, gender, disability, sexuality and class interlock’ (Razack 1995, 919; see also Baldry and Cunneen 2014). Also, as per Razack, it is important to consider how these subtexts play out, not only in the acts of violence themselves but also in the affective and legal responses to these acts of violence, particularly by police who have a central role in the criminal justice process and the ultimate recognition of violence as unlawful and impermissible.
This paper considers the criminal justice outcomes for one group of women designated as disabled who are considerably marginalised in society and in the criminal justice system (Baldry, Dowse and Clarence 2012; Dowse et al. 2015): those who have had contact with the criminal justice system as offenders (‘women offenders designated as disabled’). Paying close attention to the dynamics that shape justice outcomes for these women is important because women in this group are often victims of sexual violence. Carolyn Frohmader and Therese Sands have noted that ‘[m]ore than half of all women incarcerated in Australian prisons have a diagnosed psychosocial disability and a history of sexual victimisation’ (2015, 38). Furthermore, research suggests that there is a higher incidence of violence perpetrated against women offenders designated as disabled as compared to male offenders with disability (Baldry, Dowse and Clarence 2012; Dowse et al. 2015; Lindsay et al. 2004, 581, 585–586, 587). Rates of violence are particularly significant for Aboriginal women offenders designated as disabled (Baldry, Dowse and Clarence 2012). It is likely that the criminal justice outcomes of women offenders designated as disabled as victims of sexual violence will be affected by their contact with the criminal justice system as offenders. This is because the criminal justice system, the space through which individuals are criminalised, is also the space that women offenders with disability must be recognised as victims in order to have their complaints of sexual violence processed and ultimately recognised as unlawful and impermissible acts of violence – possibly involving the very police stations, police officers, courts and judges who have been involved with them in their capacity as offenders (see similar issue in relation to women offenders generally in Hannah-Moffat 2004, 372–376; Segrave and Carlton 2010, 292).
Mindful of Razack’s point of considering how different ‘subtexts’ interlock, this article examines the significance of women offenders with disability’s past contact with the criminal justice system as offenders (what I term the ‘subtext’ of criminality) and how this interlocks with disability and gender. To do so, I utilise the critical disability studies analytical approach to disability as ‘abnormality’. This approach directs attention to the cultural relationships between disability, gender, criminality and violence and the material and legal impacts of these cultural relationships on the bodies of women with disability, including their impact on the enactment of violence on bodies of women offenders with disability and the affective response by others to this violence which renders these acts of violence permissible and lawful.
This analytical approach is applied to an examination of the initial police contact of women offenders designated as disabled have when reporting sexual violence. For any victim this initial point of contact is significant because police determine whether a complaint will be investigated. Police also have a key role in initiating the legal process towards the state condoning (or not) this violence. For women offenders designated as disabled the initial point of police contact is of additional significance for two interrelated reasons. One is that the police force (and possibly specific individual police) may also have contact with these women as offenders, as mentioned earlier. The second is that there is a state-based centralised recording system of police contacts across offending and victim contacts (as compared to the more siloed and dispersed nature of court records) and police have the capacity to check and make reference to a woman’s record of past contacts with law enforcement, when having contact with her as a victim (as compared to court where there are strict rules of evidence and rules against judicial bias which restrict judges from explicitly drawing on a woman’s past court files in making a judicial decision). Suellen Murray and Melanie Heenan’s empirical study of police reports of rape by victims with psychiatric disability in Victoria identified past contact with police as a relevant factor in police response to complaints. However, this study did not engage in an in-depth analysis of the significance of past contact with police as an offender, nor did the authors consider women offenders with disability as a specific cohort (Murray and Heenan 2012, 357, 361, 362; see similarly Ellison et al. 2015b, 238). In examining the point of initial police contact for women offenders designated as disabled when reporting sexual violence, my focus is less on quantifying different police outcomes. Rather my analysis illuminates how discourses of disability, gender and criminality circulate in the ways police represent the women and their complaints of violence – both through words used and associated affect – and the material impacts of these representations on how these women’s complaints of violence are responded to by police.
Methodological Approach
I approach this examination methodologically by reference to the recorded police contacts of one woman offender designated as disabled by criminal justice and public health agencies: ‘Jane’. Jane has multiple contacts with police over a period of 15 years as a victim of sexual violence, alleged offender and ‘mentally ill’ person. Jane’s case study is drawn from a project consisting of ten case studies of women offenders with disability.[1] These ten case studies were derived from the ‘People with Mental Health Disorders and Cognitive Disabilities (MHDCD) in the Criminal Justice System (CJS) in NSW’ dataset (‘MHDCD dataset’) which is a cohort of 2,731 men and women who have been in prison in New South Wales, Australia, most of whom have been designated by criminal justice and public health agencies as having a cognitive impairment and/or mental illness diagnosis.[2] The MHDCD dataset contains linked data on the life-long human services and criminal justice involvement of each individual,[3] and was constructed by merging extant administrative records from criminal justice and human service agencies. All ten individuals were allocated pseudonyms. De-identified data was obtained on each individual’s demographics, criminal justice contacts, social and health factors, and disability service usage.
Two kinds of data are of primary importance here: what are referred to as ‘events narrative’, and ‘incident data’ respectively. The events narrative is the running written record of specific instances of contact an individual has had with police over their life – as an alleged offender (‘person of interest’ or ‘POI’), victim and as a ‘mentally ill person’ under civil mental health legislation. Supplementing the events narrative is the incident data which lists in tabulated form basic information on the date, reason and associated factors of each contact. Importantly, not all contacts listed in the incident data are detailed in the events narrative. Together these two forms of data were used to quantify and construct a chronology of each individual’s police contacts. The events narrative for each individual were analysed: identifying initial reason for contact (POI, victim, mental health), police perception of each individual by end of contact (POI, victim, mental health), location upon departure of police (eg custody, hospital, house) and references to and relationships between disability, gender, and criminality in how police described each contact with the individual (the ‘facts’ of the incident, the ‘facts’ of their interaction with the individual and their affective response to all of these facts).
This methodological approach differs from existing empirical studies on women with disability reporting violence to police, which have focused on sampling individual instances of victim contacts with police in a specific time period, rather than building pathways of specific women across time and all of their police contacts. For example, Murray and Heenan’s study referred to above drew on a random sample of 850 records of rape offences reported in a 3 year time period. While points did emerge about references by police to past contact as an offender or past ‘vexatious’ complaints, the authors did not consider the relationship between contacts which might make further sense of these references (Murray and Heenan 2012, 358–359; see similarly Ellison et al. 2015a; Ellison et al. 2015b 234–236). While that methodological approach usefully identifies the breadth of police victim contacts and emerging trends, it disembodies and de-temporalises the contacts and limits the significance of the findings in relation to what is happening to specific, material bodies.
Jane’s case study has been selected as the focus of discussion in this article because the high number of contacts that Jane has with police enables a particularly powerful and nuanced illumination of the relationships between contact with police as a POI, victim and ‘mentally ill person’. Through analysis of Jane’s police contacts I argue that both within specific instances of police contact as a victim of sexual violence, and across her police contacts as victim, alleged offender and ‘mentally ill’ person, Jane is constructed by police as an ‘abnormal’ body who is a drain on resources, a dishonest and nuisance offender and an attention seeker. Ultimately, it is the interlocking of discourses of gender, disability and criminality that produce Jane as unworthy of victim status and, perversely, in need of punishment by the criminal justice system.
Analysing Violence Across Discourses of Disability, Gender and Criminality: Abnormality
Analysing the significance of women offenders designated as disabled’s past contact with police as offenders (‘criminality’) to the criminal justice outcomes of these women as victims of sexual violence is not merely an exercise in searching out references by police to past criminal acts or to the women as offenders, that is, as an identity or phenomenon, separate to their disability. Rather, analytically, it requires an appreciation of the complex place of criminality in the cultural representation of disability and the material enacting of and affective responses to violence on women designated as disabled: the ‘interlocking’ nature of these discourses. This is provided by the critical disability studies approach to disability as ‘abnormality’.
Critical disability studies scholars have contested the concept of disability as a biomedical condition that resides within an individual. They argue that it is against social ideals, rather than biological norms, of human functioning and ability that disability becomes a socially constructed ‘abnormality’ (see, eg, Davis 1995; Shildrick 2009; Tremain 2002). Feminist disability scholarship has built upon this in highlighting how disabled women are constructed as abnormal at the intersections of norms of gender, ability and sexuality (Hall 2011; Garland-Thomson 2011; Shildrick 2009). Interrogation of representations of disability as abnormality involves making apparent the contingency of these representations to broader historical and geopolitical dimensions of power and inequality related to such dynamics as colonialism, neoliberalism and globalization. Disability is not analytically approached as a discrete, additional category of difference but instead is always coming into existence co-relationally with other dimensions of difference such as gender, race and sexuality in ways that reproduce the ‘normate’ subject (and in turn the nation) as white and male (Connell 2011; Erevelles 2011a; Hollinsworth 2013; Razack 2002; Soldatic 2015).
Critical disability studies scholars have explored on an abstract, discursive level the relationship between disability and criminality as deviancy in the cultural representation of disability. This is on the basis that disability as abnormality is a deviancy in constituting a failure to meet social norms (see also the critical disability-critical criminology theoretical development by Baldry and Dowse 2013; Dowse, Baldry and Snoyman 2009). Critical disability studies scholars, notably Sharon Snyder and David Mitchell, have argued that the cultural representation of disability as abnormality impacts on the social (and legal) status of people with disability (2006). Nirmala Erevelles argues that analysis of disability must consider how representations of disability as abnormality results in material violence on the actual bodies of individuals designated as disabled and how individuals marginalised on other bases such as race, gender or class disproportionately become subjected to disablement through acts of violence (Erevelles 2011a, 104–120, 142–143; Erevelles 2011b, 119, 129–132; Erevelles 2014, 96).
Critical disability studies scholars have explored how the representation of disability as abnormality impacts on how the bodies of disabled individuals are viewed and acted upon. Critical disability studies scholars have typically focused on how disability is a biopolitical category that enlivens possibilities for regulation and violence on bodies designated as disabled. While such critique has typically focused on biopolitical possibilities for normalisation to purportedly enhance life and bodily capacities (albeit directed towards predetermined ends) (Tremain 2005), recent scholarship is beginning to engage more directly with the violence of biopolitics (Mbembe 2003, 27), including the colonial and racial dimensions of confinement and other non-consensual interventions of bodies designated as disabled which position individuals for greater calculated exposure to violence and death (see, e.g., Berghs 2015; Razack 2015; Wadiwel, forthcoming). Analysis also extends to considering the carnal dimensions of law’s and other institutions’ representational and material approach to disability including how lawful techniques for regulating disability work through the body (notably through ‘therapeutic’ interventions such as sterilisation, detention, non-consensual mental health treatment) and how discourses of care, humanitarianism and benevolence which mobilise certain affective responses to the disabled body (Sullivan, forthcoming) mask the regulative, punitive, violent, indeed even lethal, effects of these interventions on disabled bodies. Moreover, their bodies designated as disabled are viewed as defective, dangerous, wasteful and a parasitical drain on public resources and a threat to the health and economic prosperity of the population as a whole. Where the sexuality and reproductive capacities of women designated as disabled present a threat of future abnormality, violence done to the bodies of women designated as disabled to curb their sexuality is a particular focus of anxiety and intervention (Titchkosky 2007, 108, 123; see also Chapman 2014, 35–36, 39–40; Garland-Thomson 2011, 21, 26; Hall 2011, 6). There is an important affective dimension to violence against people designated as disabled: how society responds to acts of violence. Shaista Patel (drawing on Judith Butler’s discussion of grievable lives) argues that people designated as disabled are viewed as ‘the excess of society, those nonhuman subjects whose lives are not worth grieving over in their pain and even in their deaths’ (Patel 2014, 207).
Analysing disability as abnormality provides an opportunity to explore (to borrow from Razack) the complex ways in which discourses of disability ‘interlocks’ with criminality in relation to police responses to women offenders designated as disabled who report sexual violence. This can go beyond a superficial analysis of criminality as equated with past instances of criminal acts, to criminality as at the core of the ontology of disability itself, as well as central to the enactment and affective responses to violence against people designated as disabled. This analytical approach foregrounds examination of the relationship between representation and police’s emotional or affective response to being confronted with the victim reports of material bodies of women designated as disabled.
Jane
Jane is a non-Indigenous woman born in the 1980s who has been labelled by criminal justice and public health agencies with diagnoses including intellectual disability and a range of psychosocial disorders including depression, conduct disorder, schizophrenia and bipolar affective disorder. She experienced multiple episodes of out of home care from the age of 4. Jane has had contact with the criminal justice system since she was a child, having around 280 recorded police contact events (as POI, victim and ‘mentally ill person’) over a 15 year period.
Jane has a considerable level of contact with police as a victim. She has around 110 police contact events with police as a victim listed in the incident data, commencing at the age of 13 years old. The overwhelming majority of these contacts are not elaborated upon in the events narrative. There are 20 sexual violence-related victim contacts detailed in the events narrative, all for non-consensual sexual intercourse. These sexual violence victim contacts receive a variety of responses. At times police investigate (for example, seek CCTV footage, request Jane undertake the sexual assault kit); at other times Jane chooses not to proceed with the matter beyond an initial report; at other times the police explicitly decide not to proceed. Significantly, there is no indication from the events narrative that any of Jane’s reports of sexual violence ever result in a person being charged or indeed any investigations that even come close to that point, including the identification of a perpetrator. Many entries in the incident data are not discussed in the events narrative, suggesting that those not included were not pursued any further than the initial contact with police.
Regardless, as will emerge from the discussion below in turn of the three types of contact that Jane has with police (victim, mental health and POI), it is not merely what outcome is achieved in relation to the report of sexual violence, but that Jane’s contact with police as a victim develop as a basis for her further criminalisation and as such the way in which police represent Jane is significant.
‘No injuries, no witnesses ...’
Throughout the events narrative of Jane’s victim contacts, there are references to the ways in which Jane fails to meet many of the stock characteristics of what feminist scholars describe as the gendered ‘ideal victim’ of ‘real rape’ (see discussion and references in Brown et al. 2015, 658–666, 677–680, 693–706). For example, there are no signs of struggle or injury, she does not appear emotionally affected, there are inconsistencies in her versions of event and her reports are uncorroborated. This is demonstrated by the following comments by police:
No injuries, no witnesses ...
Jane's version of events changed a number of times and was very vague. She did not appear to be visibly shaken or particularly upset either.
The Sexual Assault Protocol was collected. The protocol shows the victim has no visible injuries or bruising to the affected groin and leg areas. The lack of injuries supports the doubtfulness of this report. Further to this, the time it took, 2 days, for the victim to report this matter to anyone, supports that this report is doubtful. The victim’s inconsistencies in her version make it difficult to understand what really happened. Due to the victim making so many unsubstantiated reports in the past it is difficult to give any credibility to her claims.
The events narrative also reflect the ways in which disability intersects with gender to render Jane outside the ‘ideal victim of real rape’, reflecting the scholarship on sexual violence against women with disability that emphasises the significance of the intersection between gender and disability. At times, Jane’s mental health is mentioned without further elaboration, as though this per se has certain consequences for her reports, as demonstrated by the following quote: ‘report is considered doubtful due to the severe mental problems of the victim.’
At other times, police make a link between pathologised behaviour related to her disability and Jane’s reports of sexual violence:
self harm attempts and other attention seeking matters including sexual assault complaints.
... the victims [sic] history of making false allegations over a lengthy period of time. The victim also has a history of being treated for mental health problems.
The victim has an extensive history of mental illness issues, attempted suicides and has made in excess of 10 allegations of sexual assault since [7 years ago].
These references to Jane in terms of her gender and at the intersection of her gender and disability construct Jane as unbelievable and irrational, in turn invalidating her reports of sexual violence and delegitimising her as a victim. Yet, there is a need for more careful, nuanced consideration of how these ideas of irrationality and unreliability come about in the specific, material context of Jane’s contact with police. This involves turning to Jane’s criminality.
‘numerous [police record] entries’
As well as being known to police as a victim, according to the incident data Jane also has 75 contacts with police as a person of interest. Jane is charged with 37 offences (generally related to public nuisance, drug possession, property theft or damage) but only ultimately convicted of 9 of these (drug possession, non-aggravated assault, two instances of offensive behavior, theft, trespass, false representation resulting in police investigation and 2 instances of aggravated robbery). The charged property offences relate to minor theft such as taking a packet of cigarettes from a store and taking needles from a hospital. The aggravated robbery charges relate to threatening with a knife on demand of money a convenience store worker near the hospital where she had just been discharged after being held overnight for observation after having a drug overdose. The facts of the 37 charged offences relate predominantly to incidents of mental distress. One offence of making false representations resulting in police investigation related to Jane allegedly phoning 000 from a phone box at a railway station threatening self harm only to tell the ambulance officer upon arrival that she phoned 000 for a lift home. Police deal with Jane’s POI contacts primarily through the mental health system (for example, use of civil mental health powers to transport Jane to a local hospital for assessment and possible treatment), although Jane is not always admitted by the hospital and is then frequently taken home by police.
At times police refer in their narratives of victim contacts to Jane’s previous contacts with police as an offender or her current offending behaviour:
Jane has numerous [police record] entries.
Once at the hospital the victim was given a more thorough search which located numerous items of hospital items ... . She admitted stealing the property when in hospital earlier.
Jane when conveying [report] to police appeared well effected [sic] by valium and details of the alleged assault were sketchy.
The particular nature of Jane’s offending as relating to morally wrong acts of drug use and stealing further constructs her as an unbelievable (and unworthy) victim. Yet, as discussed earlier, the analytical significance of criminality to disability is not restricted to the superficial level of past acts of offending, it is also how criminality informs representations of disability in ways that both render permissible the violence against individuals with disability and delegitimise their status as ‘grievable’ victims. In order to consider these dynamics, it is important to briefly turn to the third type of contact Jane has with police: as a ‘mentally ill’ person.
‘a history of staging such antics’
Jane has a high degree of contact with police under civil mental health legislation. Police have powers under civil mental health legislation to deal coercively with individuals if they appear to have a mental illness. In particular, under this legislation police can take an individual to a hospital for assessment by a medical practitioner with the view to possibly ‘scheduling’ (that is, obtaining legal authority to coercively admit and detain) the individual to a mental health facility for involuntary containment and treatment. Criminology and legal scholars have identified the problems associated with police having these ‘public health’ powers insofar as they can result in criminalisation of incidents of mental health distress and result in long term cycling of individuals in and out of the criminal justice system (Baldry and Dowse 2013). This is apparent in Jane’s case yet with an additional, compounding effect not fully explored in the existing scholarship: the impact on her contact with police as a victim, as will now be discussed.
Jane has around 65 recorded contacts with police since the age of 19 years old which police categorise as being on the basis of mental health. Jane’s contact with police in this respect generally involves Jane phoning emergency services from her house (that is, with a general threat to kill herself, reporting overdose, threatening to jump from the roof or cut herself, or alternatively some kind of hoax such as a bomb scare) or threats made at train stations (generally to throw herself in front of a train). Police explain the ‘facts’ both of these incidents and their related contact with Jane in ways that are far removed from anything resembling empathy or concern and instead reflect a deep scepticism and trivialisation of her mental distress. In entries tinged with frustration and contempt, police refer to Jane as being motivated by attention seeking, the need for free transport and loneliness, and as generally being false and misleading, as demonstrated by the following quotes:
The POI has a history of staging such antics [self-harm] and seems to thrive on the attention given to her by the emergency services. (emphasis added)
Jane is continually tying up Emergency Services within the [area]. Jane has requested police assistance over 23 times in the past three months, mainly claiming she was about to commit suicide. (emphasis added)
Police categorise forty of Jane’s victim incidents as ‘trauma’ (just over one third). It is uncertain on what basis they identify trauma and what meaning this holds for police. Yet it is apparent that they do not view them as genuine and therefore as not requiring support and a compassionate response. Their recurring nature – an attribute of trauma – ironically becomes one of the very reasons for criminalisation of the distress as attention seeking, staged performance. Repeated contact in ‘trauma’ becomes a problem to be managed (and punished) rather than questioning why someone would constantly contact police. The affective response of frustration and suspicion – which at its worst results in arrest or simply indifference and inaction – raises questions about how police and how society at large can respond to trauma and to historical injustice in ways that are both supportive to the individual and address the structured framework within which that trauma and its causes are located. This is particularly necessary in relation to Indigenous women offenders with disability (Baldry et al. 2015, 130–135).
The affective response that police have towards Jane’s mental distress and ‘trauma’ indicates that Jane simply is not worthy of being recognised as the subject of legitimate ‘suffering’ (Cadwallader 2012). The police’s affective response also tracks onto a broader societal suspicion about people faking disability, linked to the idea of the undeserving person with disability as an intentional drain on public resources which has contemporary manifestation in scepticism about compensation sought for psychological harm (see, eg, Campbell 2006) arguably exacerbated here by reason of her dishonesty offences. Through her public expressions of distress Jane is not only not a victim in need of empathy and concern, but is obversely a deviant to be criminalised.
The majority of her contact with police is not initially nor directly related to alleged offending, but rather relates to mental health incidents, self-harm and attempted suicide, which at times escalates into or is read by police as a public nuisance and specifically as offences of property damage, assault and false calls to emergency services. On four occasions, Jane is charged with making false representations resulting in police investigation. Jane is referred to by police in the events narrative as a ‘frequent attention seeker’, a ‘habitual hoax caller’, a ‘recidivist complainer to police threatening self harm’. This criminalisation of her distress as a public nuisance constructs Jane as a parasitical drain on public resources. On one occasion when police are called to Jane’s house following a call to emergency services threatening self-harm that turned out to be a ‘hoax’, police state that:
She was told that she is to cease ringing Police with false claims. She was told that every time she rings and makes these false claims, she is taking Police away from people who really need our help and that one day she could be the cause of someone being seriously injured or killed.
Here the risk to her own life in suicide is subverted to make Jane a parasite threatening others’ lives: drawing on Patel, an ‘ungrievable’ life threatening ‘grievable’ lives. While it is acknowledged that there are different levels of seriousness of emergencies and emergency services have limited resources and that there is a lack of capability of police to handle these situations, what is of concern is that there is no recognition of Jane’s mental distress, to the point that she is criminalised.
‘Police explained to Jane the consequences of lying to Police’
The interplay of mental distress and criminalisation impacts on police perception of Jane’s reports of sexual violence. The manifestation of distress when Jane reports sexual violence is not considered genuine and is inserted into a narrative of Jane’s attention seeking and wasting police resources and time, and is also at risk of being criminalised ‘due to the mental capacity of Jane and the fact that she had made so many other doubtful similar reports, Police explained to Jane the consequences of lying to Police.’ (emphasis added)
What becomes apparent from an analysis of Jane’s police contacts as a whole is that the overarching theme running through the police response to contact with Jane is dishonesty, and while this dishonesty manifests in both criminal conduct and mental distress, it is attributed to Jane as a pathological dimension of her disability and in turn her articulations of victimisation. This is exemplified in a report by Jane of sexual assault in a public space while on day leave from a mental health facility. The police provide an unusually detailed list of reasons as to why they were not pursuing the report:
Police are treating the report of this incident as dubious for a number of reasons and they are as follows:
Points 1 and 2 reference gendered expectations about the ‘ideal victim’ related to corroboration and visible injuries. Point 3 then makes a link between her report of sexual assault and her history of false reports, her attention seeking related to mental health and her criminal charges of public mischief. Point 4 illustrates the link between disability and institutional authority because Jane has broken the mental health facility’s rules by engaging in the deviant activity of alcohol consumption and then lying to conceal it. Her challenging of the norms of power relations in mental health facilities seems to put her complaints in doubt or make her deserving of the violence (see similarly discussion of relationship between challenging behaviour, institutional authority and legitimacy of restricted practices in Dowse, forthcoming).
Disability as ‘Organising Principle’
In their essay on the police murder shooting of ‘Elanor Bumpus’, an elderly, obese, black woman with mental illness, Nirmala Erevelles and Andrea Minear argue that disability was not merely a context or magnifier to the role in the incident of Ms Bumpus’s gender, race and class. They suggest it was the organising principle that shaped the meaning attributed to these other dynamics and through which her murder by police was permissible (Erevelles and Minear 2011, 117). Likewise, my analysis of Jane’s contact with police demonstrates how criminality circulates in multiple ways but it is disability (and its associations with dishonesty and waste) which is the ‘organising principle’ across Jane’s contact with police. It is the interlocking (or, as Baldry and Dowse (2013) suggest, the ‘compounding’) nature of discourses of criminality, gender and disability in the production of disability as abnormality which ultimately magnifies the dishonesty of her complaints and secures her status as an un-‘ideal’ disabled, gendered victim and additionally encourages criminalisation of her by reason of these complaints. The way in which police represent Jane’s reports of sexual violence and her mental distress as a ‘nuisance’ and a drain on resources reduce and dehumanise her to a problem to be managed, at times punitively. Over time, reports of sexual violence and Jane’s mental distress become represented as a mundane, routine ritual to be criminalised and expected and normal for this ‘abnormal’ woman (see similarly Morin et al. 2005, 133–134), rather than as an injustice or violation to be condemned and remedied.
Looking beyond Jane’s case study, these discursive entanglements of criminality, disability and gender pervade the police events narratives of the nine other women in the sample – yet with slightly different formations (eg child familial sexual abuse, domestic violence, assault by disability service workers, violence in the context of prostitution, harassment, physical assaults) or contexts (out of home care, homelessness, drug use). The perceptions of police of their contact with these women, as recorded in the events narratives, illuminate a complex and at times contradictory interplay of dynamics: trivialising of suicide attempts and public expressions of trauma and distress, concerns for the welfare and vulnerability of these women, concerns around wastage of police and public health resources, and role of police in navigating the frequent rejection from and movement of women between various institutions (police, public health, disability services). Yet, in tracking through this project each of these women’s contact with police over time, it is not only highly concerning that a common story emerges of these women as dishonest and nuisances but that the police events narrative provides the institutional possibility for the building of and reliance on this narrative. Building on these findings, further research is required, such as through interviews or focus groups with women offenders designated as disabled and with police, to examine their perceptions of these points of contact. Further research could also delve into police organisational guidelines and training material to gain greater understanding of institutional approaches to the policing of this specific group of women, including the prioritisation of police resources, the operational relationships between police and public health and the interpretation of and reliance on the archive contained in the police events narratives.
While my analysis focused on a non-Indigenous Australian woman and on the discourses of gender disability and criminality, further research is necessary in order to situate and further develop these findings in settler-colonial violence and its contemporary rationalisations that are increasingly relying upon scientifically ‘objective’ discourses of health, disability and medicine to render interventions ‘noncolonial’ (Chapman 2014; see also Razack 2015). It is vital to interrogate how the designation as disabled consolidates and extends the necropolitical management of Indigenous Australian women offenders and the extreme (at times lethal) violence to their bodies (Razack 2002). Where Indigeneity is itself ‘lethal’, and the sexualised and racialized body of the Indigenous woman is a key site for such violence (Razack 2002), future analysis should question how the deviancy of disability heightens the exposure of Indigenous Australian women to violence and death at the same time that the inherent racism and colonialism of this violence and death is negated under the guise of individual health issues which render these circumstances inevitable (Razack 2015).
These findings have implications for current trends in criminal justice and public health to problematise individuals (particularly women) who have multiple contacts with police in relation to mental health as ‘frequent presenters’ (see, eg, Baldry, Dowse and Clarence 2012). There is a need to explore the relationship of the category of frequent presenter as a quantifier of service overuse to the material, economic dimensions of disability as abnormality and its association with waste (Erevelles 2011a, 143) and possible links to neoliberalism in reduction of state and public care and support (Soldatic and Meekosha 2012; Kendall 2004, 280). This exploration could draw on critical disability scholarship on disability and temporality (see, eg, Kafer 2013). Critical interrogation of the category of ‘frequent presenter’ and of criminalisation of trauma more broadly is particularly pertinent in light of the current Australian Royal Commission into Institutional Responses to Child Sexual Abuse. The Commission recently released a consultation paper on criminal justice issues which focuses on criminal justice responses to the acts of child sexual abuse (Royal Commission, 2016). While these are essential criminal justice matters to consider, my article gestures towards the criminal justice issues related to the subsequent criminalisation of the public displays of trauma and distress by those victims of institutional sexual abuse who (possibly by very reason of their abuse in which the state was complicit) are disabled and have ongoing contact with the criminal justice system as offenders and under civil mental health legislation. Approaching police responses to this group in the broader context of the past violence and injustices in which the state might be complicit raises further complexities about the (in)justice inherent in contemporary punitive responses to these women by the state (via the police): suggesting here a violent and punitive disavowal of state responsibility.
Ultimately, there is a need to challenge the complex relations of disability, criminality, gender and sexuality that leave bodies subject to lawful violence and punished for their attempts to seek assistance from police. Building on the feminist scholarship and activism that has illuminated the significance of norms of gender and sexuality to the justice outcomes for women victims of sexual violence, there is a need to interrogate the cultural constructions of ability and criminality to justice outcomes of women offenders designated as disabled (noting that only examining disability alone and not also its intersections with criminality could legitimise violence against ‘deviant’ women with disability (Bromwich 2015, 204–209)). While this article has focused on police perception and affect by reference to critical disability scholarship, a further point of critical intervention could be the feminist scholarship on listening and epistemic injustice (Fricker 2007; for an exploration of epistemic injustice in the context of disability, see Matthews, forthcoming). In part this would involve interrogating the possibility of ‘othering’ within this feminist theory itself and the risk that women who are both criminalised and disabled fall outside of the margins of this theory (notably because neither of categories are explicitly considered by Fricker). Yet beyond the specific issue of the appropriate police response to women like Jane, there is a much larger issue in need of urgent consideration: the ethical and affective response of abled members of society to individual encounters with criminalised and disabled lives already deemed ungrievable. Following from Erevelles’ question, drawing on Judith Butler; ‘what bodies matter and which are yet to matter’ (Erevelles 2011a, 6–7) – we need to ask why the violence to women offenders with disability does not matter and demand that it does.
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Notes
1 Ethics approval was granted by the University of Wollongong Human Research Ethics Committee (HE14/168), and ratified by the University of New South Wales Human Research Ethics Committee.
[2] This study is a nested study within the Australian Research Council (ARC) Linkage project, 'People with Mental Health Disorders and Cognitive Disabilities (MHDCD) in the Criminal Justice System (CJS) in NSW', University of NSW – Chief Investigators E. Baldry, L. Dowse and I. Webster. Ethics approval was obtained from all of the relevant ethics bodies, including from the University of New South Wales Human Research Ethics Committee. See generally Australians with MHDCD in the CJS Project (29 June 2012) Mental Health Disorders and Cognitive Disabilities in the Criminal Justice System http://www.mhdcd.unsw.edu.au/australians-mhdcd-cjs-project.html. See also (Baldry, Dowse, and Clarence 2012).
[3] The cohort was drawn from the 2001 NSW Inmate Health Survey (IHS) and from the NSW Department of Corrective Services State-wide Disability Service Database (SDD).
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