Assessing the Costs of False Allegations of Child Abuse: A Prescriptive

Susan Kiss Sarnoff*

It is a sad truth that policymakers often demonstrate greater concern for the financial costs of policies than for their human costs. This is certainly true of the costs of false allegations of child sexual abuse. Policymakers rarely demonstrate concern about false charges unless they are exposed. Lawsuits against government entities are now increasingly permitted as well, as was shown by the unsuccessful attempts by Kathleen Coulbourn Faller, and seven of her staff members at the University of Michigan Family Assessment Center (FAC), to avoid civil charges of malpractice by arguing that, as state employees, they were immune to such charges.

But charges of malpractice are difficult to prove, as the clearing of Faller and the University of Michigan demonstrated. Despite videotapes showing staffer Jane Mildred using leading questions and an anatomically-detailed doll and even allowing the child's (accusing) mother to participate in an interview designed to determine if the child's father was sexually abusing her, jurors were apparently swayed by the fact that the FAC staff were "good, hard-working professionals trying to take care of children," according to one of their attorneys.

Yet these professionals failed to detect paranoia on the part of the mother (manifested so blatantly that the judge in the case ignored the FAC's report and gave custody to the child's father). The judge had no difficulty recognizing that a mother who regularly inspected her child's genitals and took her for no fewer than eight physical examinations to detect abuse, none of which were successful, was pathologically obsessed with the fear that her child was being molested. This demonstrates a clear discrepancy between the public's perception of professionals, as defined by their credentials and the settings in which they work, and an understanding of the skills and qualities professionals in child welfare require to effectively perform their roles.

The judge and jury in the malpractice trial, however, were not aware that leading questions and suggestive objects, such as anatomical dolls, often create "false positive" findings of abuse.¹ Moreover, Faller is among a handful of child sexual abuse "evaluators" (she was herself a founder of the now-defunct Believe the Children) who professes that child sexual abuse is far more common than is recognized, and who ideologically lean toward true findings of abuse.² Given the sloppiness reported in the case that was the subject of the malpractice lawsuit, it gives pause to realize that Faller's center has seen over 1,000 children since 1978, and that none of these cases have been reviewed to determine whether later facts supported or disproved its findings.

Yet false allegations accrue considerable — and wholly unnecessary — costs to all aspects of the criminal justice and social service systems, potentially for police and other investigatory procedures, prosecutorial and court operations, pretrial incarceration costs, foster care and out-patient or residential treatment, indigent defenses and public assistance for the accused's family. It also accrues costs to the falsely accused, for legal fees, lost wages, and mandated counseling. Perhaps the worst cost of all is that increased attention to false allegations is beginning to threaten the public's faith in all child abuse investigations.

These costs vary for many reasons, in particular the time and other resources allocated. Unfortunately, even rough amounts are impossible to calculate, because there is no agreement about how many people have been falsely charged. The nature of child abuse investigations, however, make them particularly likely to accrue high systemic costs, and to reflect an excess of false positives because, when hard evidence is not available, or conflicting accounts emerge, the children are often referred to "evaluators," who claim to have special expertise in interviewing children and eliciting their reports of abuse. Some of these evaluators do have particular skill in developing rapport with children and encouraging them to express themselves. But, as the ritual satanic abuse witch hunts of the past decade demonstrated, too many of those who call themselves evaluation "experts" are really ideologically-driven validators, who assume that abuse occurred and then use spurious methods to convince others of what they have already convinced themselves.

As Bucks County District Attorney Alan Rubinstein's extensive investigation disproving allegations of ritual abuse at the Breezy Point Day School demonstrated, children's statements, whether elicited by parents, evaluators, or others, can be proved or disproved — but such investigations are costly, as Rubinstein is the first to admit. Rubinstein did pioneering work in this area, and compiled his results in a report which offers guidelines for others — and exposes a bogus expert in ritual satanic abuse.³ Sadly, too few professionals know of the existence of this report. But while costly to investigate, false allegations are also costly to prosecute, because the falsely accused are much more likely to insist on trials, while the guilty more often opt for plea agreements, which tend to carry more lenient sentences.⁴

Ideologues cannot alone turn false allegations into false convictions. But when validators are used as hired guns by the prosecution, and when defense attorneys and judges fail to challenge their assertions, the costs of false allegations can escalate to those of false convictions, including incarceration, probation, parole and appeal costs. False convictions, in turn, usually engender requests for new trials or appeals. And when these are successful, they can lead to civil and even criminal litigation against the experts whose testimony led to the convictions as well as against government entities that were complicit with the experts.⁵

The falsely convicted may also be entitled to compensation. Five states — California, Illinois, New York, Tennessee and Wisconsin — provide such compensation as a right.⁶ This may affect the conditions under which compensation is offered, as well. For instance, Ohio offered Jenny Wilcox, who spent almost 12 years in prison based on the coerced testimony of children about a crime that never occurred (the children recanted to their mother even before the trial was completed, and she worked for Jenny's release),⁷ a mere $300,000 in compensation — if she agreed to hold the state harmless for any other damages.⁸ In contrast, Kerry Kotler received $1.5 million from New York for his conviction, which was overturned when DNA proved that he had been misidentified. Yet Kotler was on trial for another rape, of which he was convicted, when he obtained the funds — he claims that the second rape charge was engineered as "payback" because his exoneration had embarrassed Suffolk County.⁹ Many states also avoid paying compensation to the falsely convicted by overturning convictions for what they label "technicalities," holding the specter of retrial over the erroneously convicted instead of acknowledging their innocence.¹⁰

The costs discussed so far, too, are unquantifiable, not only because the actual costs of investigations and trials vary so greatly, but because most falsely convicted people are never identified. If their cases are not reheard they are considered guilty, and if their convictions are overturned, their innocence is still not necessarily assumed — they are often compensated in agreements that are sealed from public view. And these costs do not even constitute the bulk of the actual and potential costs that false allegations force the system to accrue.

In half of all child abuse cases, the child "victims" receive counseling.¹¹ Often parents, and sometimes siblings and others close to the child, also receive counseling.¹² If the parents do not have insurance to pay for these services, state crime victim compensation programs assume the costs.¹³ My doctoral research identified the fact that child victim cases are the least likely to be turned down — when these cases go unpaid by public funds it is almost always because other resources are available to pay for these services.¹⁴ And other resources are provided at so many different levels through so many different, uncoordinated means — private insurance, Medicaid, and so forth — that it would be impossible to quantify them without studying the individual case files of hundreds of separate private, state and federal agencies.¹⁵

These cases are so rarely turned down, in fact, that they are routinely paid even when the allegations of abuse occurred during an acrimonious divorce, or in a day care or other case later found to be a hoax.¹⁶ Victim compensation, and most forms of insurance, were designed to be available to meet urgent medical needs, and for this reason, it is provided long before case outcomes are decided.¹⁷ While compensation agencies have the right to independently investigate cases that have not been fully investigated by other agencies, they rarely doubt the veracity of children — even when the children's statements are actually reported by parents or interpreted by dubious court experts.¹⁸ And at least one state's compensation agency, Washington's, briefly covered adult claims based on recovered memories of child sexual abuse.¹⁹ (It is possible that other states have paid such claims, as well, although no data exist on this possibility.)

But no compensation or criminal justice agency has developed mechanisms to review case outcomes later to determine whether the crimes on which they were based were actually found to have occurred.²⁰ California's victim compensation agency paid over 200 claims filed by families who accused Dale Akiki of abusing children at a church-run day care facility, resulting in at least $200,000 in therapy payments, although Akiki was later acquitted. The agency did review the claims, but decided to pay them because, according to Deputy Director Curt Soderland, "Just because somebody isn't convicted, doesn't mean something didn't occur." Yet Akiki's case was also reviewed by a number of journalists and policymakers, who found that his indictment alone was an egregious miscarriage of justice.²¹ (In fact, the prison guards assigned to Akiki spent their own funds to send him home in a limousine upon his release. Anyone who understands the cynicism of prison guards will see that this was an unprecedented vote of confidence in Akiki's innocence.) The San Diego County Grand Jury's independent investigation into the Akiki prosecution also reported that it had been based upon faulty assumptions, faulty practices and overzealous attempts at "case finding."²²

The same Grand Jury investigated the case of Jim Wade, who was accused of raping and sodomizing his 8-year-old daughter. Although the daughter claimed that a stranger had abducted her after climbing through her bedroom window, the child was placed in foster care for 13 months, at state expense, during which time she was repeatedly encouraged by her foster parents and her court-appointed (and state paid) counselor to admit that her father had abused her. At the same time, Wade was required to enter — and pay for — sex offender therapy while proclaiming his innocence. The case was resolved only when DNA cleared Wade — and identified as the actual assailant a man the child's counselor knew to have committed similar crimes in the Wades' apartment complex.²³ The counselor did later surrender her license (on the eve of having it removed)²⁴ — but not before hundreds of thousands of dollars had been unnecessarily expended on this single case.

Both the Child Abuse Prevention and Treatment Act (CAPTA) and the Violence Against Women Act (VAWA) encourage detection and case finding.²⁵ But CAPTA long ago shifted its focus from physical violence against children, which is relatively easy to detect, to sexual and other types of abuse that are more difficult to identify — and failed to either develop technologies to detect such abuse or to provide adequate training and salaries to lure well-trained professionals into the field.²⁶ Yet, both VAWA and CAPTA key their funding to detecting cases, encouraging zealous case creation.

For example, Ohio has refused to review the conviction of Ron Tijerina, imprisoned for allegedly sexually abusing his younger brother-in-law, Dan Mohr, although Mohr has recanted in a formal deposition. Court-based victim advocate Sally King assisted Mohr's mother to obtain victim compensation for Mohr's therapy, arguing that Mohr's emotional and drug problems began when he met Tijerina. Yet the advocate had proof that Mohr's problems predated his meeting Tijerina by several years, which she withheld from the defense, and Ohio's compensation agency refused to review this case, even though Mohr admitted that his false allegations were prompted by a promise of victim compensation benefits.²⁷

That zealous case creation occurs is also demonstrated by the great increase in such cases that have been identified since these acts were passed and by the much smaller comparative increase in cases that have resulted in convictions.²⁸ However, cases of child and spousal abuse that lack sufficient evidence for criminal prosecution are often referred to the Family Court system, where the San Diego Grand Jury found that, "the burden of proof, contrary to every other area of our judicial system, is on the alleged perpetrator to prove his innocence. [As a result,] a parent making a false allegation of abuse or molest[ation] during a custody dispute is very likely to achieve the desired result."²⁹ A subsequent jury largely concurred with these findings.³⁰

Despite insistence on the part of some few victim ideologues that, "children never lie about sexual abuse," journalist Cathy Young has observed that, "FBI statistics indicate that eight to nine percent of rape reports are 'unfounded' — closed because the complainant recants or investigators conclude that no crime was committed, [while] the rate for all crimes is around two percent."³¹ These figures translate into more than 8000 false rape reports each year.³² Even Manhattan Sex Crimes Prosecutor Linda Fairstein has observed that, "False reports of rape do occur. . . [and] have made it difficult for legitimate victims to be taken seriously. . . . For all prosecutors . . . it is critical to acknowledge that false accusations of rape are made."³³

But the discrepancy between the proportion of false reports of sexual and nonsexual crimes may not result from women's desires to falsely allege sex crimes, but instead, may respond to the system's incentives to do so. These follow from the unintended consequences of policies which are so sensitive to victims that compensation and even criminal justice officials are discouraged from conducting any kind of investigation of victims' veracity,³⁴ as well as the fact that sex crimes frequently leave as little tangible evidence as does whiplash, which is also often faked simply because it is so difficult to verify or disprove.³⁵

That compensation fraud may be most common in the areas of child abuse and sexual assault claims is also suggested by the fact that these services receive the bulk of program funds (76%, considerably more than the 30% mandated), and also receive a significant portion of direct compensation (30% of awards and 18.7% of funds),³⁶ as well as targeted funds from CAPTA, VAWA and the Department of Health and Human Services, suggesting how numerous claims based on these allegations are.

The Akiki case and a handful of others like it, including the notorious McMartin Preschool case, did convince California's victim compensation program to limit therapy payments to a maximum of $10,000 per victim.³⁷ But this is a poor solution; it not only fails to weed out incompetent and even fraudulent counselors, it might even encourage them to find more cases to balance their loss of revenue per victim. In California, too, child abuse claims increased by 225% from 1984 through 1994, making them the major draw on the fund — a fund which consistently had to be bailed out by taxpayers or face annual multimillion dollar shortfalls.³⁸ In fact, in 1990 a special report commissioned by the California State Board of Control to study child molestation claims observed that "rarely is there independent, conclusive corroboration for [child molestation]. Physical evidence is present in only about 15% of the[se] cases." The same report also observed that counseling is required by fewer than 20% of victims.³⁹ And the National Association of Crime Victim Compensation Boards found that, while mental health claims based on child victims were increasing in all states, California's rate of increase was still 50% to 100% greater than those of other states.⁴⁰ One reason that this may be so is that, in California, evaluators are often blacklisted if they fail to support the position of the child protection agency in dependency or abuse hearings.⁴¹

These cases threatened to bankrupt almost all state compensation programs just a few years ago.⁴² They did, in fact, cause long delays in victims' receipt of payments, and kept payment maximums for other expense categories, such as funerals, at the same level for years (decades in some cases).⁴³ Ironically, however, large deposits in the federal Victims of Crime fund last year, from a small number of high corporate fines, increased the size of the fund substantially at the same time that crime rates dropped. As a result, victim assistance programs alone received $400 million in federal funds in 1997 (in contrast to $688 million over the prior ten years).⁴⁴ These increased funds, coupled with the drop in crime rates, make it unlikely that victim compensation agencies will question any claims, because they have to justify their receipt of federal funds with matching state payments to victims.

While only a handful of ritual sexual abuse day care hoaxes have actually led to convictions (most of which have since been overturned) even those that resulted in acquittals, like Akiki's, reflect hundreds of children and their family members who were referred to counseling.⁴⁵ In many of these cases, the families were limited to a handful of approved counselors, who also helped police and prosecutors investigate the cases by eliciting testimony from the children.⁴⁶ One must wonder what these counselors counsel these children about, particularly in the cases in which the allegations were later proved to have come from them rather than from the children with whom they worked — and considering that the children in these cases began showing symptoms of abuse only after disclosing — the reverse of abused children's usual responses to counseling.⁴⁷

Another less recognized result of the day care hoaxes was that they forced other day care centers to obtain heavy insurance coverage, which forced many out of business entirely, and may have increased the incentives to defraud the remaining ones.⁴⁸ As a result, some areas of the country, particularly southern California, have limited if any congregate day care. This requires working mothers to pay more for individual day care (which actually makes child abuse more likely and less easy to detect), and is another hidden cost of the false allegations of abuse.⁴⁹

Why do victim compensation agencies refuse to recognize (or acknowledge) that many of these cases were fabricated by the very mental health professionals who are the only people to benefit from them? Perhaps because the federal government and the National Association of Crime Victim Compensation Boards have encouraged compensation agencies and victim advocates to form partnerships.⁵⁰ These partnerships have become so cozy in some states that victim advocates hold a majority of seats on advisory councils, plan and present workshops at state conferences, train police, prosecutors and compensation and child protection agency staff, evaluate victims to determine whether abuse occurred, treat those whom they determine were abused and then verify that the abuse constituted a crime reimbursable by the state victim compensation program,⁵¹ and even coach victims' testimony.⁵²

While only the last of these actions is patently illegal, all raise questions about conflicts of interest and states' abilities to maintain the arm's length distance that their fiduciary responsibilities dictate. The dangerous effects of such close relationships are evident in California's inability to distinguish between cases in which somebody wasn't convicted and that subset of those in which something didn't occur, as well as in the New York State Crime Victim Board's presentation of a workshop on Ritual Sexual Abuse at its 1997 conference⁵³ — fully five years after the FBI's seven-year, multimillion dollar study which concluded that ritual sexual abuse was virtually nonexistent.⁵⁴

It is obvious that continual reliance on the same handful of experts to report on innovations in the field, train others in their application, and even determine which claims are compensable dangerously skews decision-making toward the perceptions, or misperceptions, of a limited number of like-minded ideologues, for whom each founded case of child abuse contributes to their program statistics, their personal incomes, and their personal beliefs in the widespread (and even satanic) nature of child sexual abuse. But the partnerships (or collusion) among victim advocates, the staff of compensation programs and so-called experts also creates a stonewall which makes it less likely that the inappropriate extremes of these partnerships will be disclosed.

Many of these experts have been found to misrepresent or ignore existing research in their fields, in part because they lack experience with issues other than sexual abuse which can produce similar behavioral indicators in children.⁵⁵ In fact, in many cases these experts claim that their field is child sexual abuse, having no grounding in broader (and licensed) mental health fields that would have acquainted them with normal child behavior or the range of traumas that can cause similar reactions in children. Their defense is often that child abuse warrants such zealous prosecution, denying that those accused should be granted the same rights as those accused of other crimes.

But their primary error is in believing that such indicators can be of any use in identifying the perpetrators of the abuse. As a result, they are easily manipulated into diverting suspicion from actual offenders, creating suspicion in retaliation for perceived wrongs, or simply abetting scams against well-insured day care centers and public and private insurers. And their concern that child abuse is so rampant, but hidden (to all but themselves) is belied by the fact that child sexual abusers are the most recidivist of criminals, who are quite likely to be identified eventually without resort to questionable methods that rarely withstand appellate review.⁵⁶

Thomas Sowell pointed out in a recent column that, "no factual record is kept of how often [court experts] are proved wrong by later events."⁵⁷ Police officers, who are assessed in part on the rate of crimes that they clear, and prosecutors, who are similarly rated on their proportion of guilty verdicts not later overturned on appeal, understand how case post mortems demonstrate the true effectiveness of the criminal justice system and its participants, and maintain a balance between zealous crime fighting and preservation of the rights of those accused.

Yet, eventually, the rates of effectiveness of the least expert tend to be exposed in malpractice lawsuits, license review procedures, and in some cases, even criminal prosecutions. Media reports of such procedures are, sadly, often the first notice to other victims (including the government agencies that unwittingly rely on these experts) that the procedures they used were faulty. By then, however, the damage has occurred, and the costs have been incurred. But the costs of undoing the damage, which can be considerable, will threaten to present themselves for some time to come.

Peter Huber observed in Galileo's Revenge, the book in which he coined the term "junk science," however, that civil litigation is most effective as a threat which encourages solving problems by other means.⁵⁸ Civil litigation also ignores the systemic problems which enable false allegations to proceed through the system unchecked. For a system to actually learn from the hoaxes and misinterpretations of the past, it must create feedback loops to ensure that the information it receives about individual cases and the state-of-the-art of case investigation is both accurate and complete. Well-meant incompetence in the earliest of these cases should be studied for its effects on later perceptions of these crimes and the methods by which they are investigated.

But obvious hoaxes, created or perpetuated by experts, should also be investigated to ensure that compensation and other benefits that were provided because of false allegations are recovered, that defrauders are identified and dealt with, and that the same practitioners are no longer counseling the children they erroneously identified as victims. In fact, the ongoing counseling of these children should be paid for out of these practitioners' malpractice insurance, or other restitution collected from them on the children's behalf by victim compensation programs. In this way, the resources intended for real victims will be preserved for them, future malpractice of this sort will be deterred, and the integrity of the criminal justice and victim assistance systems will once again deserve the trust of the entire community. Furthermore, experts who caused children who demonstrated no indication of victimization to undergo intrusive medical examinations and psychological interrogations should be criminally prosecuted for child abuse.

One final step should be taken to complete the feedback loop. Victim compensation agencies should be empowered to compensate the victims of false allegations as well as the falsely convicted in every state. It is only when victim compensation agencies bear the costs of false allegations that they will gain the incentive to prevent all such cases, and not just to address the handful that gain media attention. This feedback loop would finally, and quite appropriately, recognize the falsely convicted as victims of crime, because the stigma of being falsely accused of a crime, and the horror of being wrongly imprisoned, is one of the worst forms of victimization — and one that is in the government's power to rectify.

1. Jack Kresnak. "UM Clinic Cleared in Child Evaluation. Father Loses Lawsuit Over Abuse Inquiry." Detroit Free Press, November 26, 1997; Jack Kresnak. "A Father Is Suing Sex-Abuse Evaluators at a UM Clinic, Claiming That Leading Questions and a False Report Damaged His Daughter," Detroit Free Press, November 3, 1997.  [Back]

2. Debbie Nathan and Michael Snedeker. Satan's Silence (). NY: Basic Books, 1995.  [Back]

3. Alan M. Rubenstein. Report: Investigation into Breezy Point Day School. Doylestown, PA: Office of the District Attorney, March 1990.  [Back]

4. Charles Silberman. Criminal Violence, Criminal Justice ()(). NY: Random House, 1978.  [Back]

5. For example, the False Memory Syndrome Foundation Newsletter and the Justice Committee (San Diego, CA) have documented thousands of such cases.  [Back]

6. C. Ronald Huff, Arye Rattner and Edward Sagarin. Convicted But Innocent ()(). Thousand Oaks, CA: Sage Publications, 1996.  [Back]

7. Marianne McMullen. "Cry for Justice," Dayton Voice, February 21-27, 1996.  [Back]

8. Author's conversation with Jenny Wilcox, December 1997.  [Back]

9. Chau Lam & Donna Porstner. "Back to Prison," Newsday, July 18, 1997; Robin Topping. "Kotler Gets $1.5 Million for Wrongful Conviction," Newsday, July 4, 1997; Paul Vitello. "One Trial, But Two Planets," Newsday, July 3, 1997; "Wrong-Man "Rapist" Awarded $1.5 Million," New York Post, July 4, 1997.  [Back]

10. See, for example, Debbie Nathan and Michael Snedeker. op. cit.; David Stout. "Conviction for Child Abuse Overturned 10 Years Later," New York Times, September 30, 1997.  [Back]

11. Ted R. Miller, Mark A. Cohen and Brian Wiersema. Victim Costs and Consequences: A New Look. Washington, DC. National Institute of Justice, February 1996.  [Back]

12. National Association of Crime Victim Compensation Boards. 1997 Program Directory. Arlington, VA: National Association of Crime Victim Compensation Boards, 1997.  [Back]

13. Susan Kiss Sarnoff. A National Survey of State Crime Victim Compensation Programs. Ann Arbor, MI: University Microfilm International, 1994.  [Back]

14. Ibid.  [Back]

15. Susan Kiss Sarnoff. Paying for Crime: The Policies and Possibilities of Crime Victim Reimbursement (). Westport, CT: Praeger Publishers, 1996.  [Back]

16. Susan Kiss Sarnoff. op. cit., 1994.  [Back]

17. Ibid.  [Back]

18. Joe Cantlupe and David Hasemyer. "Akiki Case Drains Victim Fund: With No Crime, Should Therapy Be Paid?" San Diego Union-Tribune, January 31, 1994.  [Back]

19. Elizabeth F. Loftus. "Repressed Memory Accusations: Devastated Families and Devastated Patients," Journal of Applied Cognitive Psychology, Vol. II, 25-30, 1997.  [Back]

20. Susan Kiss Sarnoff. op. cit., 1994.  [Back]

21. See, for example, Debbie Nathan and Michael Snedeker. op. cit.; and Joe Cantlupe and David Hasemyer. op. cit.  [Back]

22. San Diego County Grand Jury. Analysis of Child Molestation Issues. Report No. 7. San Diego , CA: San Diego County Grand Jury, June 1, 1994.  [Back]

23. John Wilkens. "Innocent Family Awaits End to Child-Abuse Saga." San Diego Union-Tribune, November 14, 1993; San Diego Grand Jury. Families in Crisis, Report No. 2. San Diego, CA: San Diego Grand Jury, Assessing the Costs of False Allegations of Child Abuse: A Prescriptive.  [Back]

24. John Wilkens and Jim Okerblom. "Rape-Case Therapist Gives Up License," San Diego Union-Tribune, March 20, 1996.  [Back]

25. Steven Smith and Susan Freinkel. Adjusting the Balance: Federal Policy and Victim Services (). Westport, CT: Greenwood Press, 1988; Grants to Combat Violent Crime Against Women: Proposed Regulations. Washington, DC: U.S. Department of Justice, 1994.  [Back]

26. Steven Smith and Susan Freinkel. op. cit.  [Back]

27. Susan Sarnoff, "In Defiance of Justice," OACDL Vindicator, Summer 1997.  [Back]

28. See, for example, Cathy Young. Ceasefire: Beyond the Gender Wars (). NY: Free Press (in press).  [Back]

29. San Diego County Grand Jury. Child Sexual Abuse, Assault, and Molest Issues, Report No. 8, San Diego, CA: San Diego County Grand Jury, June 29, 1992.  [Back]

30. San Diego County Grand Jury. op. cit., 1994.  [Back]

31. Cathy Young. op. cit.  [Back]

32. Alan M. Dershowitz. The Abuse Excuse (). NY: Little, Brown & Company, 1994.  [Back]

33. Linda Fairstein. Sexual Violence ()(). NY: William Morrow and Co., Inc., 1993.  [Back]

34. Susan Kiss Sarnoff. op. cit., 1996.  [Back]

35. Ken Dornstein. Accidentally, On Purpose ()(). NY: St. Martin's Press, 1996.  [Back]

36. Susan Kiss Sarnoff. op. cit., 1994.  [Back]

37. Joe Cantlupe and David Hasemyer. op. cit.  [Back]

38. Joe Cantlupe. "Cash-Short Victim Fund Gets $44 Million Bailout," San Diego Union-Tribune, January 29, 1994.  [Back]

39. Lucy Berliner and Benjamin E. Saunders. Management of VOC Child Molest Claims. Sacramento, CA: State Board of Control, June 30, 1990.  [Back]

40. National Association of Crime Victim Compensation Boards. "Recent Trends from VOCA Performance Reports," Crime Victim Compensation Quarterly, No. 1, 1993.  [Back]

41. Santa Clara Grand Jury. Final Report 1992-93. Santa Clara, CA: Santa Clara Grand Jury, 1993; San Diego Grand Jury. op. cit., February 6, 1992.  [Back]

42. Susan Kiss Sarnoff, op. cit., 1996.  [Back]

43. National Association of Crime Victim Compensation Boards. op. cit., 1997.  [Back]

44. State Crime Victim Compensation and Assistance Programs," OVC Fact Sheet. Washington, DC: U.S. Department of Justice, undated.  [Back]

45. Debbie Nathan and Michael Snedeker, op. cit.; Cantlupe, op. cit.; Cantlupe and Hasemyer, op. cit.; San Diego County Grand Jury, op. cit. June 1994.  [Back]

46. See, for example, Debbie Nathan and Michael Snedeker, op. cit.; Stephen J. Ceci and Maggie Bruck. Jeopardy in the Courtroom: A Scientific Analysis of Children's Testimony (). Hyattsville, MD: American Psychological Association, 1995; and San Diego County Grand Jury. op. cit., 1994; San Diego County Grand Jury. op. cit. February 6, 1992; and San Diego County Grand Jury, Families in Crisis, Report No. 2 Supplement. San Diego, CA: San Diego Grand Jury, June 29, 1992.  [Back]

47. Debbie Nathan and Michael Snedeker, op. cit.  [Back]

48. Increasingly, the day care centers that have been targeted for allegations of ritual sexual abuse have been heavily insured or have high real estate values. See, for example, Mark Pendergast. Victims of Memory (). Hinesburg, VT: Upper Access, Inc., 1995.  [Back]

49. Jeffrey S. Victor. Satanic Panic ()(). Chicago, IL: Open Court Press, 1993.  [Back]

50. Compensation and Assistance: Working Together," Crime Victim Compensation Quarterly, Spring 1996.  [Back]

51. San Diego County Grand Jury 1996-1997. "Victims of Crime Program in San Diego County," Final Report. San Diego, CA: San Diego County Grand Jury, 1997.  [Back]

52. See, for example, Raymond Hughes. "Protest Path," New Hampshire News-Leader, August 15, 1996; Susan Sarnoff, "In Defiance of Justice," OACDL Vindicator, Summer 1997; Mitch Weiss. "Citizens Group Casts Doubt on Victims Aid," Cleveland Plain-Dealer, September 17, 1995.  [Back]

53. New York State Crime Victims Board. Conference Brochure. Albany, NY: New York State Crime Victims Board, 1997.  [Back]

54. Kenneth Lanning. Investigator's Guide to Allegations of "Ritual" Child Abuse. Quantico, VA: National Center for the Analysis of Violent Crime, January 1992.  [Back]

55. Letter to Morton Stavis from Dr. Suzanne Sgroi regarding Eileen Treacy's testimony in the Margaret Kelly Michaels case; deposition of Dr. Roland Summit regarding Joseph and Laurie Braga's testimony in the Bob Fijnje case.  [Back]

56. A. Nicholas Groth. "Patterns of Sexual Assault Against Children and Adolescents," and Suzanne M. Sgroi. "Child Sexual Assault: Some Guidelines for Intervention and Assessment," in Ann Wolbert Burgess, A. Nicholas Groth, Lynda Lytle Holmstrom and Suzanne Sgroi, eds. Sexual Assault of Children and Adolescents ()(). Lexington, MA: D. C. Heath, 1985.  [Back]

57. Thomas Sowell. "Victims of the 'Helping Professions'," New York Post, December 27, 1997.  [Back]

58. Peter Huber. Galileo's Revenge (). NY: Basic Books, 1991.  [Back]