Behavioral Sciences and the Law

Behav. Sci. Law, 16, 525±533 (1998)

Book Review
Hope for Law: Narrative
Therapy and Intimate
Abuse Practice
Linda G. Mills, Ph.D., L.C.S.W., J.D.*

A Review of Narrative Therapy in Practice: The Archaeology of Hope

edited by Gerald Monk, John Winslade, Kathie Crocket, and David Epston. Jossey
Bass, San Francisco, CA (1997), 320pp.

Leila is a 24 year old Maori1 woman who had been hospitalized by Dr. Glen
Simblett, a psychiatrist, in New Zealand. Leila had been hallucinating. Dr. Simblett
felt that her psychotic episodes had become so life threatening that she needed
hospitalization. While hospitalized, she stopped talking, eating, and drinking.
Against medical advice, she refused treatment. Ultimately, she checked herself
out of the hospital to see a tohunga (a Maori healer). Leila described her story as
follows:
Tigers have 9 lives. It lost its ®rst life in the family it was born in because of their
abuse and punishment. It lost its second life to drugs and alcohol. She [sic] lost her
third life in a marriage where there was no room for her hopes and ideas. She lost her
last life when she was admitted to a psychiatric unit. She hasn't got many lives left now
(p. 122).
Dr. Simblett is a psychiatrist practising Narrative Therapy in New Zealand. Leila
was, in part, the inspiration for Dr. Simblett's commitment to Narrative Therapy
and to a psychiatric practice that is sensitive to the cultural, ®nancial, and gendered
subtexts of emotional breakdown and to their narratives, as the clients themselves
embrace them.
Leila's story is part of an edited volume titled Narrative Therapy in Practice:
The Archaeology of Hope. The book is a fascinating collection of therapy practice-
based essays written by New Zealand counselors engaged in a form of therapeutic
practice called Narrative Therapy. Narrative Therapy develops a postmodern
method of counseling which relies on both therapist and client narratives for
de®ning the presenting problem and for proposing solutions. The book presents
essays on both the theory and practice of Narrative Therapy, a method which has
now been adopted by postmodern therapists who practice in all parts of the world.
The ®rst four chapters of the book describe the theory and method of Narrative
Therapy, and the last six chapters present its application in a number of practice

* Correspondence to: Linda G. Mills, Department of Social Welfare, School of Public Policy and Social
Research, 3250 Public Policy Bldg., Los Angeles, CA 90095-1656, USA. Email: lmills@ucla.edu
1
The Maori people are a Polynesian group that inhabited New Zealand before European colonists
arrived 300 years ago.

CCC 0735±3936/98/040525±09$17.50
# 1998 John Wiley & Sons, Ltd.
526 Book Review

settings including psychiatry, alcohol treatment, therapy with male sexual abuse
survivors, school counseling, group counseling using indigenous knowledge, and
mediation. While the speci®c application of Narrative Therapy as therapeutic
practice may have only marginal interest to the readership of an interdisciplinary
journal involving law and behavioral science, the method of Narrative Therapy has
much to teach advocates who are interested in an engaged legal practice, one that
provides more than a typical legal solution. This review essay presents the method
of Narrative Therapy as it is described in the text and explores Narrative Therapy's
application to an intimate abuse legal practice.
Lawyers, more speci®cally, and the legal system in general, rob clients of their
lives every day. Fighting for one's Social Security bene®ts can involve several
appeals and numerous rejections. Getting a worker's compensation settlement can
take seven years. Suing for medical malpractice involves depositions, court appear-
ances, and testimony from hostile doctors. Often, lawyers themselves exacerbate
the su€ering of their clients by misdirecting them or by failing to nurture them
through the treacherous legal process (Durston & Mills, 1996). Indeed, in Robert
Cover's prophetic words ``[T]he relationship between legal interpretation and the
in¯iction of pain remains operative even in the most routine of legal acts'' (Cover,
1986).
Recently, a number of scholars have attempted to construct a more hospitable
and caring legal system (Goodrich, 1996; Littleton, 1993; Margulies, 1995; Mills,
1998; Wexler & Winick, 1996). Using principles from psychology, psychoanalysis,
philosophy and critical and feminist studies, these scholars struggle to create a
more empowering space from which clients can engage the law.
Narrative Therapy in Practice: The Archaeology of Hope o€ers a number of con-
crete methods by which emotionally minded lawyers can help clients work through
their legal problems in ways that ®nd satisfactory resolutionsÐresolutions that
actually help the client heal from the trauma that evoked legal intervention in the ®rst
place. Those practitioners who ®nd themselves hostile to the idea that the legal
system can and should be therapeutic and healing should avoid this text. This book,
and the work of narrative therapists in general, is only for the psychologically
sympathetic lawyer, for the advocate who believes that the legal system has an ethical
or even legal mandate to respond in ways that do not rob Leila of her nine lives.

NARRATIVE THERAPY IN PRACTICE:

THE ARCHAEOLOGY OF HOPE

Several chapters in the book explore the theoretical underpinnings of the Narrative
Therapy approach. Chapter 3 most clearly outlines a method. It is helpful to
understand the method and to explore how it might be applied in a legal context.
Narrative Therapy, described in some detail below, grows out of postmodernism,
a philosophy which rejects notions of ``certainty'', ``truth'', and the idea that
we can ever really know anything. Postmodernism recognizes that there is no
``essence'' or essential being. Language or speech, as it is interpreted by post-
modernists, is not an expression of knowing beings but rather a re¯ection of the
larger social, political, and cultural conditions in which it is created. Meaning then
is both tentative and uncertain. Postmodernism is fundamentally political in nature,

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
 Book Review 527

insofar as it questionsÐit reveals the unspoken gendered, racial, or cultural

dynamics which underpin interactions. Deconstruction is a method by which a
more appropriate, or less veiled, interpretation of the subtext of dynamics or
language is revealed.
According to Narrative Therapy in Practice: The Archaeology of Hope, post-
modernism in Narrative Therapy adopts a position of uncertainty as to meaning or
essences and of protest against the backdrop of modernist thought. One of its
central tenets is that meaning is socially constructed insofar as it is embedded in the
social, political, and cultural conditions in which it is created. Stories and their
accompanying metaphors, according to Narrative Therapy, expose those hidden
subtexts or meanings when they are revealed in counseling. ``Helpers'', that is,
counselors or therapists, are trained to hear the stories people tell about themselves
and the stories others tell about them, both of which shape the client's experience
in the world. Narrative Therapy suggests that people experiencing emotional
problems are part of, or located in, their stories. These stories are ``constructed'',
not essential or fated. Unlike the more typical therapeutic interaction, the goal of
the helper is not to respond to the problem story with an interpretation, insight, or
intervention. Rather, the purpose of Narrative Therapy is to help the client
develop a story he or she prefers. In this endeavour, the helper co-authors the
preferred story and a positive outcome is hopefully achieved.
Several techniques are used in Narrative Therapy to help elicit the client's story
and to help the client author a preferred narrative. I describe these techniques in
the lexicon in which they are presented in the book.

The Terms
``Preferred Descriptions'' give therapists an opportunity to explore their own
stories and to rediscover their preferred descriptions of themselves as counselors.
Professional training often renders even the therapist's previous life experience
invisible.2 Key to e€ective Narrative Therapy practice is the assumption that if
helpers are to learn more about their client's stories, they must be familiar with
their own. Lawyers, as I have previously argued could bene®t tremendously from
such self-re¯exivity and from learning more about how their own stories permeate
the choices they o€er clients.3
``Persistent and Genuine Curiosity'' is key to the practice of Narrative Therapy.
The idea is that the helper's curiosity should encourage the client to reveal both
their negative and positive storyÐtheir su€erings and their competencies. To guard
against abusive interrogations and to achieve a more respectful curiosity, Narrative
Therapy suggests that helpers ask clients whether they are willing to proceed with a
line of questioning and that helpers ``check in'' as the questioning persists. This
ensures, as is key to Narrative Therapy, that clients are willing participants in
presenting their stories. It seems obvious that lawyers could bene®t from taking a

2
Similarly, law training often represses the student's personal experiences and renders them invisible or
irrelevant. Students are taught to eliminate the ``I'' from their arguments, to repress their feelings about
the facts of a case, and to present their arguments in a gender neutral manner. See, for example,
Goodrich, 1986; Guinier et al., 1997; Kennedy, 1992.
3
For a discussion of countertransference as technique for insight-oriented lawyering, see Mills, 1996,
1997, 1998.

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
528 Book Review

more tentative posture when questioning clients about their legal stories; and while
this may be controversial, it might also be bene®cial if lawyers considered both their
client's su€erings and competencies when exploring how to proceed in a given case,
especially when the client involved is likely to be marginalized or rendered invisible
by the legal process.4
According to Narrative Therapy in Practice: The Archaeology of Hope, discourse,
positioning, deconstruction, and reconstruction are the methods or tools around
which a client's narratives are assembled. Discourse is a ``cluster of ideas produced
within the wider culture'' (p. 93). ``Discourses'' are stories which embody cultural
norms and which reveal, when examined closely, the power dynamics in both
intimate and social relations. ``Positioning'' is integral to discourses insofar as the
discourses themselves position us in relationship to others. In other words, where
we are situated in a given story line, or position, is dictated by the discourse.
The inevitable interplay of these concepts is best illustrated through an example.
A battered woman and her abusive partner share a certain discourse about their
dynamic which positions them in relation to each other. The batterer, for example,
may believe that he is ``king of his castle''. Without re¯ection, the battered woman
may capitulate to this version of what is expected of her.
The discourse which underlies their story probably takes various forms. For
example, the batterer may feel entitled to a warm cooked meal because he is the
primary breadwinner. The battered woman may unre¯exively agree and ``buy into''
this discourse. This discourse positions them in con¯ict, and quite possibly in
danger, when the battered woman fails to prepare dinner according to his speci®-
cations. No excuse is adequate to counteract the ``I am king'' discourse. A colicky
3-month-old, a job obligation, or a dying mother only rei®es the ``king'' discourse
and her position in it. Together they have unwittingly agreed to the story which
takes precedence over all others: that he is king.
``Deconstruction'' disassembles the discourses, the assumptions which underpin
a dynamic. Indeed, in the example, deconstruction inverts the binary opposition
between ``king'' and ``cook'', and prepares the client for the possibility of rejecting
the destructive dynamic. Deconstruction provides an opportunity for the battered
woman to see what she has agreed to and to re¯ect on her position within that
discourse. The purpose of deconstruction is to pull the curtain away, to reveal the
power dynamics which lie behind the discourse. ``Deconstruction is a process in
which discourses are exposed and people's positions within them are revealed''
(p. 95).
``Reconstruction'' is the space of possibility, the opportunity revealed from the
deconstruction process. Reconstruction occurs when the client has revealed the
discourses and the positioning and is now ready (and able) to reconstruct her story
in ways she chooses. Reconstruction allows the client to reject the cultural and
social norms and other assumptions embedded in the discourse she has unwittingly
adopted and enables her deliberately to reposition herself in ways that are
constructive and ful®lling. Reconstruction creates the possibility of reversing the
hierarchical opposition. In the case of the battered woman, reconstruction enables
her to reorder the discourses, and to reposition herself within them. It enables her,
at least emotionally speaking, to choose a story she prefers. The law, in whatever

4
For an insightful method for hearing the client's strengths, See Al®eri, 1991.

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
 Book Review 529

form it takes, such as a restraining order or arrest, may or may not ®gure in to her
new story. Lawyers, strictly speaking, may or may not be instrumental in helping
this battered woman move on with her life.
For the psychologically minded lawyer, Narrative Therapy should be viewed as
an exciting new development in the theoretics of legal practice. It has promise both
for client interviewing and for assisting clients in resolving their problems in ways
that move beyond the law, and which envision a more meaningful and ful®lling
resolution.5

The Case Example of Intimate Abuse:

What Does Narrative Therapy Have to O€er Law?
Lawyers in general, and political lawyers in particular, are responsible, for
``hearing'' the stories, the narratives, of their clients. Articles abound which suggest
that lawyers fail to hear the subtext of clients' stories and to respond to the subtle
meaning within their clients' narratives (see, e.g., White, 1992; Al®eri, 1991;
Durston & Mills, 1996). This has been particularly evident in the area of domestic
violence practice, a disturbing development given the threat intimate abuse poses to
the women who seek legal assistance (see, e.g., Margulies, 1995; Mills, 1996, 1997,
1998).
These misunderstandings are exacerbated when lawyers and clients cross cultural
divides.6 Lawyers come to these interactions with their own racial or gendered
interpretations or narratives, and clients come with their own discourses. Ill
equipped to talk across cultural di€erences, even well intentioned lawyers mis-
interpret the stories of people of color. In domestic violence cases, these fault lines
can inadvertently reposition a battered woman in a violet episode, or even in a life-
threatening situation.7
It is useful to explore how Narrative Therapy's principles might help lawyers and
clients talk across cultural and other divides. To deconstruct how lawyers might use
Narrative Therapy in their interactions with battered women, I use the characters
and stories from the popular movie, ``Once Were Warriors''. ``Once were Warriors''
is a particularly poignant example, as the movie is ®lmed in New Zealand and
portrays the dicult life of the Maori people. Similarly, Narrative Therapy in
Practice: The Archaeology of Hope is edited by counselors practising in New
Zealand and is a therapeutic method designed, at least in part, to address the unique
cultural and emotional needs of the Maori people.
``Once Were Warriors'', directed by Lee Tamahori, is a ®lm about many things.
It is about the Maoris as warriors, as strong indigenous people with deep cultural
roots. Like many indigenous people, however, the ®lm depicts the destruction
of a culture and the impact that destruction has had on individual lives. The ®lm
exposes the Maori people's dependency on alcohol, drugs, and the dole, all of
which provide little hope for a better life. Most striking, and indicative of the
devastation brought by colonization, is the fact that Maoris make up 12% of
5
For one exploration of alternative methods for resolving legal con¯ict, see Minow, 1997.
6
For an insightful analysis of these issues, see Lopez, 1992.
7
One study of white and black batterers in Milwaukee revealed that race is a critical factor when
determining the ecacy of arrest policies and yet, it is rarely factored into the decisions of police ocers.
See Sherman et al., 1992.

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
530 Book Review

the population of New Zealand, while representing 99% of the prison population
(Shulman, 1996).
Given my work in domestic violence, and more particularly my interest in the
cross-cultural dimensions of intimate abuse, for me the movie centers on Beth
Heke. Beth Heke, a Maori woman, played by actress Rena Owen, has been married
to Jake Heke (Temuera Morrison), a Maori man, for 18 years and has ®ve children
with him. The movie is a portrait of Jake's violent outbursts (he is nicknamed
``Jake the Mus'' for muscle), both in bars and at home, and his inability to control
his violent temper.
Moreover, the movie is about the e€ect of that violence on their children. Their
oldest son, Nig, joins a gang (distinguished by body tattoos in the Maori tradition),
and his younger brother, Boogy, is placed in a state foster-care institution. Their
daughter, Grace, who ultimately commits suicide, is raped by her father's uncle.
While the movie is only marginally about the legal system (Boogy is sent to a
state institution after a brief court hearing), it is possible to imagine that in this day
and age Beth Heke, as a battered woman, might have been exposed to the legal
system, should she have needed or wanted it following a violent episode. Indeed,
one domestic violence program in New Zealand called the Hamilton Abuse Inter-
vention Project is speci®cally designed to address the unique legal and other needs
of battered Maori women and their children. How might Narrative Therapy help
these emerging legal and therapeutic programs address battered women's needs?
What we learn from the movie is that Beth Heke ultimately ®nds her strength by
rediscovering her cultural roots. What is revealed is that she left her Maori village
18 years earlier to marry Jake. At the time she left, her father, a traditional Maori,
disapproved of her marriage and prophesied that ``she would return''. In her
stubbornness, as the movie portrays her, she saved face by never returning. What
she ultimately realizes, is that it is in her cultural heritage that she can rediscover
her strength and identity. Can the law be e€ective in helping a battered woman like
Beth Heke ®nd this healing path?
United States legal narratives in domestic violence are all too often undimen-
sional. The legal system only knows the law; it does not have the tools or capacity to
help women ®nd their ways to safety through other means. This, I argue, is the
promise of Narrative Therapy. It can o€er lawyers and their clients tools which can
facilitate long-lasting change, with or without legal intervention.
Battered women, in general, hesitate to seek assistance. When they do, their
interactions are often dissatisfying, all too often sending them toward, rather than
away from, the abusive relationship (see Mills, 1998). Had Beth Heke approached
the legal system and been faced with a lawyer trained in Narrative Therapy, that
lawyer might have been able to help her see that the most healing path for her in
relation to the violence in her life is a cultural one. Using principles of Narrative
Therapy, how might such an interaction unfold?
Critical to a dialogue with a woman like Beth Heke is a lawyer's re¯ection
on her own ``preferred description''. As I have previously argued, knowing one's
countertransferences (what the lawyer brings in terms of a psychological history to
the legal interaction) is critical to ensuring that those issues are not transferred in
terms of an emotional history onto the client (Mills, 1996, 1997, 1998). For
example, an advocate who has not re¯ected on her own issues may project her own
interpretation of a situation onto her client. One battered woman may prefer legal

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
 Book Review 531

intervention, another may want to rely on therapeutic or cultural support to bolster

her internal strength. If the advocate is of the legal interventionist type, she may be
inclined to direct her client toward legal assistance, both because she is comfortable
with it and because she herself prefers it (see Mills, 1998). When an advocate
explores her own ``preferred descriptions'', she becomes aware of her own stories,
her own propensities, and her own inclinations. She then can monitor those
stories and inclinations to ensure that in her meetings with battered women those
stories or inclinations do not in¯uence how the client is advised. Hence, using a
Narrative Therapy approach, the client is allowed the opportunity in the legal
interview to explore what legal or other strategies would work best for her.
The use of ``persistent and genuine curiosity'' is a technique that will also
enlighten conversations between lawyers and battered women. This tool allows the
advocate or lawyer to help the battered woman reveal both the positive and negative
stories in her life, the competencies and the su€erings. This is key in a domestic
violence case. Battered women's advocates all too often focus on the victim's
negative history. In doing so, they marginalize, or render invisible, the survivor's
positive history with the batterer. The battered woman then harbors those positive
feelings silently; they brew. These repressions begin to in¯uence her behavior and
her desire to return. However, if the battered woman is allowed the opportunity to
discuss both the negative and positive dimensions of her relationship, she can
explore more fully how she wants to respond. By hiding nothing, the battered
woman feels free to make informed decisions based both on the su€erings and
competencies of the relationship.
``Discourse'', ``positioning'', ``deconstruction'', and ``reconstruction'' can also
be critical tools for helping the battered woman discover what intervention is
appropriate for her. For example, if you are not Maori and you are the advocate,
you may be unfamiliar with the underpinnings of that cultural discourse; even if
you are Maori and are familiar with the culture, you may not be familiar with Beth
Heke's personal story. Discourse work would enable the advocate to learn more
about how Beth Heke positions herself within her story and the story of her family.
Drawing from the story line in the movie, Beth Heke's biography is deeply
in¯uenced by her cultural heritage and by the ``warrior'' qualities evident in Maori
history. The movie reveals that Beth did not feel that she could return to her
indigenous roots and to her family village because she had resolved as a young
married woman that she would not make her father right. She eventually identi®es
this stubbornness as a strength or a more positive repositioning of her discourse;
this deconstruction of her history as warrior is what became her foundation for
having the strength to leave Jake.
Endemic to her shift away from Jake, and her realization that Jake was a
destructive force in her life, was her deconstruction of Jake's violence. In the
beginning of the movie, one imagines Beth's discourse as sympathetic to Jake,
making excuses for his violence. Beth becomes ready to question her sympathies
when her daughter Grace suicides and when her sons leave. In these losses, Beth
restories Jake's violence, not as warrior-like, but as negative and weak. She says
``You brought [that violence] home; that violence killed my Grace''. In their ®nal
confrontation, this repositioning through discourse is especially evident when Beth
responds to Jake's question ``where are you going?''. She says ``I found something
better. I make the decisions for my family. Our people once were warriors, people

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
532 Book Review

with pride, spirit. If my spirit can survive living with you for 18 years, then I can
survive anything''.
While Beth came to these realizations on her own, it is critical to wonder
whether the legal system might not have helped her ®nd this reconstruction sooner.
The legal system is often the ®rst point of contact for battered women. I am
suggesting that the tools of Narrative Therapy, including persistent and genuine
curiosity, discourse and positioning, and deconstruction and reconstruction, might
have helped a legal advocate working with Beth Heke ®nd a life free from violence
through her cultural reconnection. Indeed, these realizations may have occurred
before Grace's death and before Beth experienced the loss of her sons.
Drawing on Beth's history, a lawyer using Narrative Therapy techniques might
have elicited discourses about her past, both positive and negative, in which Beth
revealed her su€ering and her strength. When Beth could see her strength in these
negative and positive narratives, she might then be poised to care of herself and her
children, and she might then be positioned to reject Jake's violence. In the movie,
these deconstructions and reconstructions ultimately enable Beth to create a
narrative which is free from Jake's violence.
Legal intervention in Beth Heke's case may or may not have assisted her in
keeping her and her children safe. No doubt her resolve to change her life went well
beyond the typical legal response which o€ers restraining orders, arrest, and even a
few referrals. Indeed, Beth Heke changed her life without the law. However, given
the law's more recent propensity to intervene, it seems reasonable to suggest
alternative methods or tools for advocates who become involved in these cases.8
What seems clear is that a lawyer may have been in a position, had she been trained
in Narrative Therapy, to become involved earlier and to have helped women like
Beth Heke to take therapeutic journeys in realizing paths to healing. In this case, it
was not the law Beth needed, but rather a helper who could see, along with her,
that cultural reconnection was her most likely salvation. What Narrative Therapy
o€ers the lawyer is a method for looking beyond the law, if necessary, and for
helping women like Beth Heke to see that tigers' lives can be re-claimed in the
strength that lie sleeping in their su€ering.

ACKNOWLEDGEMENT

Dr. Mills is Associate Professor of Social Welfare and Lecturer-in-Law at UCLA.

I owe a debt to David Wexler who encouraged me to read this somewhat obscure,
and moving book. Thanks also to Peter Goodrich who always helps deconstruct my
narratives.

REFERENCES
Al®eri, A. V. (1991). Reconstructive poverty law practice: learning lessons of client narrative,
Yale Law Journal 100, 2107.
Cover, R. M. (1986). Violence and the word, Yale Law Journal 95, 1601.

8
Many of the United States' e€orts in the last 20 years have been aimed at encouraging law enforcement
to take domestic violence seriously. While I agree that such intervention is necessary, I believe it should
be tempered according to the wishes of the battered woman, assuming that she is in a position to make
such decisions.

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)
 Book Review 533

Durston, L., & Mills, L. (1996). Toward a new dynamic in poverty client empowerment: The
rhetoric, politics, and therapeutics of opening statements in social security disability hearings, Yale
Jornal of Law & Feminism, 8, 119.
Goodrich, P. (1996). Law in the courts of love: Andreas Capellanus and the judgements of love,
Stanford Law Review, 48, 633.
Goodrich, P. (1986). Reading the law: a critical introduction to legal method and technique, Blackwell
Publishers.
Guinier, L., Fine, M., & Balin, J. (1997). Becoming gentlemen: women, law school, and institutional
change, Beacon Press.
Kennedy, D. (1992). Legal education as training for hierarchy. In (David Kairys (Ed.), 1992).
The politics of law (p. 38), Pantheon.
Lopez, G. (1992). Rebellious lawyering: one chicano's vision of progressive law practice. Westview Press.
Littleton, C. Women's experience and the problem of transition. In (Martha Minow (Ed.), 1993).
Family matters: readings on family lives and the law p. 261.
Margulies, P. (1995). Representation of domestic violence survivors as a new paradigm of poverty law:
In search of access, connection, and voice, George Washington Law Review, 63 1971.
Mills, L. G. (1996). On the other side of silence: e€ective lawyering for intimate abuse, Cornell Law
Review 86, 1225.
Mills, L. G. (1997). Instituition and insight: a new job description for the battered woman's
prosecutor and other more modest proposals, UCLA Women's Law Journal, 7 169.
Mills, L. G. (1998). The heart of intimate abuse: new interventions in child welfare, criminal justice, and
health settings, Springer Publishing Co.
Sherman, L. W. et al. (1992). The variable e€ects of arrest on criminal careers: the Milwaukee
domestic violence experiment, Journal of Criminal Law and Criminology 83, 137.
Shulman, K. For Actress Rena Owen, `Warriors' is more than a role in movies: the 34-year-old Maori
has personal experience with the cultural subjugation portrayed in the ®lm About New Zealand's
indigenous people, (1995, March 10). Los Angeles Times F. 10.
Wexler, D. B. & Winick B. J. (Eds.). (1996) Law in a therapeutic key: developments in therapeutic
jurisprudence. Carolina Academic.
White, L. (1992). Theoretics of practice: the integration of progressive thought and action: paradox,
piece-work, and patience, Hastings Law Journal 43, 853.

# 1998 John Wiley & Sons, Ltd. Behav. Sci. Law, 16, 525±533 (1998)