Can A Victim's Voice Reduce Crime?
It's Victims' Rights Week. So what-the-hell... I'll preview a draft of my final paper for my justice administration course, which is the final course for my graduate degree.
I've gotten less-and-less interested in victims issues, and more involved in the entire justice puzzle, but I chose this topic because I thought - all things considered, given everything - it was a fitting way to conclude my studies. All comments are appreciated:
The Influence of Victim Impact Statements on Sentencing and Parole Decisions
The crime victim is the initial nexus in a criminal justice process that can span years, if not decades. Without a victim there would be no offender, no crime, no police investigation… No trial with judge, jury and lawyers, no sentence nor incarceration, no rehabilitation with parole and eventual release. Nevertheless, despite this initial flashpoint, the criminal justice process has little to do with the victim. In the court system, criminal wrongdoing is presented as an offence against the public interest. Thus though the court’s starring player is the crime victim – without whom none of the legal proceedings would commence or even be necessary – the offense is against the state, and the victim is quickly relegated to the role of functional observer of the events that lead to his or her own victimization. Though victim and offender are often set against each other on a one-to-one basis in the criminal procedure, in the last 100 years the parity in terms of social services has gradually shifted to favor the offender. Offenders are the beneficiaries of drug treatment, job placement, psychological counseling, anger management; all welfare programs designed to rehabilitate the criminal wrongdoer. The 1980s and 90s witnessed the birth of a victims' rights movement in the United States, designed to tip that balance back to equitably provide the same sort of social assistance to crime victims. The initial wave of these reforms focused on victims' rights in terms of recognition within the criminal justice process. As expressed by Edna Erez, a leading scholar of victim research, “victim participation will provide recognition of the victim’s wishes for parity status and individual dignity” (Henderson, 1985, in Erez 1990: p.365). Basically these reforms can be boiled down to formal communication procedures where victims were notified of offender sentencing, parole, release, etc…. The latter half of the 1990s saw a gradual shift from recognition rights to participatory reform. Having been invited to the table, victims now wanted the opportunity to actually influence criminal justice decisions, especially in the areas of sentencing and parole (Smith and Huff, 1992; Viano, 1987). Nowhere has this shift in policy been more apparent than in the use of Victims Impact Statements (VIS). Though conceived as a method for criminal justice influence, the VIS quickly became a tool of cathartic release for crime victims. At sentencing, crime victims were given the opportunity to stand before judge and jury and describe – in written or oral statement – how the offences of the accused had adversely impacted their lives. Success with VISs was measured by the degree that expressing the feelings and frustrations against offenders brought internal satisfaction to the victims. Only recently, through Supreme Court decisions in the late 1980s and early 1990s which allowed VISs to be presented at capital sentencings, have VISs been permitted to fully evolve toward their initial intended purpose: tools for victims to influence the punishment of offenders. Currently all 50 states and the District of Columbia allow for written victim impact statements to be presented at sentencing and parole hearings, oral presentations of VISs are permitted at sentencings in some states, though they are more commonly permitted by states during parole proceedings.
Victim Impact Statements in the Courts
The use of victim impact statements in legal proceedings has been shaped by three United States Supreme Court rulings. In Booth v. Maryland (1987), John Booth was convicted of the first-degree murder of an elderly couple. At sentencing, the victims’ family gave an emotional and detailed account of how Booth had forever negatively impacted the lives of the family. Booth was ultimately sentenced to die. However the sentence was challenged, and by a 5-4 decision the Supreme Court struck down the decision on the grounds that it unfairly influenced the jurors’ objectivity:
[VIS] information is irrelevant to a capital sentencing decision, and its admission creates a constitutionally unacceptable risk that the jury may impose the death penalty in an arbitrary and capricious manner.
In South Carolina v. Gathers (1989) a murder conviction again was overturned by the Supreme Court (again by a 5-4 decision), and again because of a perceived prejudicial presentation of a victim impact statement at the sentencing phase of the trial:
The prosecutor's comments concerned the victim's personal characteristics, and "[a]llowing the jury to rely on [this information] . . . could result in imposing the death sentence because of factors about which the defendant was unaware. 
Finally, in a 6-3 decision, Payne v. Tennessee (1991) ruled in favor of the state and reversed the rulings in both Booth and Gathers. In his majority decision, Chief Justice William Rehnquist determined that “victim impact evidence is simply another form or method of informing the sentencing authority about the specific harm caused by the crime in question”. The Court’s ruling not only granted the right to introduce written VISs, but to present oral statements. Further, the ruling set the precedent for VISs to be used in non-capital cases, and also during parole hearings. These U.S. Supreme Court decisions set the table for increased victim influence over the justice system. How effective that influence has become is the subject of much debate.
Victim Impact Statements at Sentencing
The earliest studies on victim participation in the criminal process tended to measure success outcomes in terms of victims' perceptions. Anthony Walsh in his analysis of sexual assault victims’ perceived influence on offender sentences, Placebo Justice concludes that victim impact statements are a “mere genuflection to ritualistic legalism”. In his study of over 400 Ohio felony cases Walsh found that sentences were mostly impacted by offense severity and offenders’ prior record, and that VISs had a limited influence. Nevertheless, Walsh argues that there is a placebo value in these statements in that they leave an impression on victims that “something is being done”, and that their concerns are being taken seriously (Walsh, 1986: 1139). Walsh also raises the question as to whether victims should even have any influence over the sentencing process:
Victims certainly deserve more consideration by the law and its agents, but the law cannot simply become the instrument of their revenge. (Walsh, 1986:1139)
For Walsh, the players in the justice equation – victim, offender, the system – must find equilibrium so that no party exercises undue influence over another (Walsh, 1986: 1139).
The issue of sentence disparity is one of the chief criticisms against the use of victim impact statements. Opponents of victim integration in the justice system argue VISs cannot be implemented uniformly, and therefore is prejudicial to offenders (Grabosky, 1987; Hellerstein, 1989). For example, some victims are willing to file statements, while others are not (Hall, 1991; Sims, Yost & Abbott, 2005). Still others are more articulate in expressing themselves, and thereby may be more influential in pleading their cases (Morgan, Smith, 2005). Ironically it was Chief Justice Rehnquist in the Payne v. Tennessee ruling who first touched on this disparity declaring, “two equally blameworthy defendants may be punished differently solely on the basis of the harm caused.” Rehnquist apparently had no unease with this disparity, but the issue has sparked controversy. Most notably, opponents of the use of VISs warn of the danger of some crime victims using the statements vengefully to seek retributive justice (Sebba, 1985), which is in contrast to the initial inspiration for using VISs to make victims feel whole again.
Despite these concerns, research has demonstrated that the issue of sentence disparity could be irrelevant given victim impact statements have been shown to have little influence on court sentencing. In their study of 500 felony cases in Ohio, Erez and Tontodonato (1990) found that VISs had some effect on sentence outcomes, but - consistent with Walsh (1986) - the primary influences to sentencing were the nature of the offense, and offender characteristics. Also, Victim requests for longer sentences played no importance in sentencing outcomes. Further, the study found support for prior findings that victims were not unduly punitive and vengeful (Forst and Hernon, 1985; Hough and Moxon, 1985; in Erze and Tontodonato, 1990: 467). Erze and Tontodonato also found that few victims showed an interest in giving an oral VIS, but this may be in part due to a majority of the cases being victims of property crimes, a less severe felony where victims have shown little interest in participating in the justice process. Consistent with Tice (1985), Erze and Tontodonato reasoned that VISs may have minimal impact on sentencing because judges had already made a sentencing decision prior to the delivery of the VIS. Thus, the sentencing session is “ritualistic in nature”, and the victim’s rights are largely “symbolic” in this process. In their concluding remarks the authors agreed with Walsh’s assessment of victim impact on court proceedings as Placebo Justice, stating the characterization was “consistent with reality”. Subsequent studies have borne similar results; the victim impact statement has little effect on sentence severity or whether an offender is sentenced to prison or probation (Davis and Smith, 1994a; Erez and Roeger, 1995).
Alan Young points out that if disparity exists the fault is not with victim participation, but with disparate sentencing guidelines:
Sentencing disparity exists as a result of our reliance upon discretionary sentencing structures, and the solution to this problem lies not in the muzzling of victims but in a movement towards more determinate sentencing structures.
Young, writing from a Canadian policy based framework, argues that the research of Americans Hellerstein (1989) and Hall (1991) have determined that victim impact statements are irrelevant to the discussion of sentence influence because the U.S. court system had already moved to presumptive, determinate sentencing where VISs have shown to have no impact (Young, 2001: 11). Though Young may assume the U.S. system pre-determines sentencing, United States v. Booker deemed Federal Sentencing Guidelines to be unconstitutional. In the wake of Booker, these guidelines have become little more than suggestions on how a judge should determine sentencing, allowing judges to apply a discretionary amount of “reasonableness” which the court left undefined.
Despite some standardization to criminal sentencing, a great degree of disparity exists on how judges in different jurisdictions apply sentences for similar crimes. In the studies that have been done to date, little attention has been given to the influence of victim impact statements on court systems with determinate sentencing compared to those systems where judges are permitted to exercise greater flexibility in sentencing. More research is needed to see if in fact, when judges and juries are allowed to impose harsher punishment, the victim impact statement influences the court to do so.
Victim Impact Statements at Parole Hearings
In a 2005 editorial commentary on victims rights policy in Criminology, Senior Editor, James W. Marquart identified inclusion of victims in the parole process as, “… a major, but relatively, unnoticed byproduct of the victims’ rights movement.”.  One reason may be that many states have moved from parole to determinate sentencing. Nevertheless, despite a gap in research, some academic work has been done on VISs and parole. In 1989 Maureen McLeod interviewed parole administrators in several states and determined that victim impact statements had a perceived effect on parole outcomes. One administrator commented that “personal appearances have more of an effect than written statements” McLeod 1989 in Morgan and Smith 2005: p. 339).
William Parsonage et al’s 1989 study of 200 Pennsylvania parole cases revealed that victim testimony had a significant impact on parole release decisions.  The researchers found that VISs were not only informative, providing information that could determine if an inmate could be released, but also supplementary; where the victim’s testimony could enhance the parole board’s decision with further sentencing (Parsonage et al, 1992: 14). Because Pennsylvania law does not specify how victim impact statements should be used in the parole decision making process, the writers warn of two potential concerns that could arise through the use of VISs. First, the authors argue that VISs are potentially prejudicial in that victim testimony “may be colored by the victim’s own fears and concerns” (Parsonage et al, 1992: 14). Parsonage et al suggest that the VIS be viewed objectively within the entire context of parole decision making, and become part of the contextual process in order to avoid discretionary bias (Parsonage et al, 1992: 14). Second, and in terms of enhanced sentencing, the authors caution that if the victim’s testimony is used to enhance sentencing - at the exclusion of the risk to the community - then again, the process could be offering too much discretionary power to the parole board (Parsonage et al, 1992: 14).
In keeping with Parsonage, Morgan and Smith’s 2005 study of 792 Alabama felony offenders found victims' influence to be a predictive factor in the parole decision making process. Morgan and Smith also warn of the policy implications inherent in their findings. Again, with Parsonage, because of the broad range of discretion permitted by parole boards to allow VISs to influence the decision making process, the authors argue that victim influence should be one of several factors used to determine parole outcomes:
To what extent will parole boards allow victim influence to override the concerns for the inmate? Is it fair to further punish an inmate who presents a low risk of recidivism for future criminal behavior because victims show up at hearings to protest the release?
Morgan and Smith conclude with a recommendation for further investigation of victim influence in the parole process; specifically:
2. Is there a difference between victim satisfaction at sentencing versus parole?
3. Are parole releases higher in states with poor victim services (such as notification and oral VIS)?
In a reaction essay to the Morgan and Smith findings, Laura J. Moriarty raises, then refutes several concerns about the use of victim impact statements in parole hearings. First, is the often-raised caution that the VIS process is a format for re-victimization: retelling their story will force victims to relive a painful memory cause psychological damage to victims. Citing the work of James Pennebaker, Moriarty argues that for some victims retelling a painful story can actually be therapeutic, and the act of repetitive iteration can defuse and dissipate the pain associated with memory.  Moriarty also raises the caution that the inconsistent use of VISs at parole hearings, “constitute a due process violation” for offenders (2005: 388). Moriarty counter-argues (somewhat unrealistically) that the solution to this problem is to move toward full participation of all victims in the parole process. Perhaps a better argument is suggested by Alan Young who offers that the denial of victim participation constitutes a due process violation for the victim, and that neither exclusion nor full inclusion is the solution to victim-offender parity:
“…victim participation is inherently valuable because of the due process value of fostering dignity through participation in a decision making process that has direct relevance to one’s welfare interests.” (Young, 2001: 11)
In summary two broad themes emerge in an analysis of the use of victim impact statements in the rubric of sentencing and parole decision-making. First is the larger issue of victim participation, and resultant inequities that may emerge when victims are, or are not involved in these justice decision processes. Second is the high degree of discretion afforded to the agents in this decision process and how inequities in this first issue may tip the balance of these decisions, resulting in even greater inequity. Unequal participation is a serious concern since, at its roots, the victim rights movement was designed to be inclusive. As Chad Trulson suggests, “The bottom line, however, is that exclusion is everywhere.” Though it easy to see why some victims may opt out of the system due to relatively low personal impact crimes (property crimes, some victimless crimes), the issue of low participation with more serious offenses is more complex and possibly related to victims’ satisfaction. Sarah Goodrum suggests that the reason for low victim participation in what some would consider the most severe and personally traumatic of offenses, murder, may be tied to the frank reality that the initiation into the justice process involving murder is such a bummer to begin with. Goodrum notes that despite a wealth of research on victim satisfaction, few studies have asked victims to describe their experiences with the justice system.  Goodrum argues that because bereaved victims and law enforcement perceive murder from such different perspectives - and because law enforcement has all the power in the relationship - when they come together, these victims quickly become disillusioned, disenfranchised and alienated from the criminal justice system (Goodrum, 2007: 727). Citing Skolnick, Goodrum suggests this initial jolt is so disarming that it becomes virtually impossible to ever bring some victims back into the fold:
In many ways, all victims – not just bereaved victims – are at the mercy of law enforcement detectives handling their cases, and there is little they can do to change that…. Police hold tremendous discretionary power over which actions to investigate and how (Skolnick 1994). Skolnick writes “an extremely important jurisprudential fact [is]: it is impossible to eliminate discretion entirely from the administration of criminal law” 972). Some argue that this discretion is the cornerstone of police work, allowing officers to consider circumstances and follow hunches; it may also be the cornerstone of victims’ problems with the criminal justice system. (Goodrum, 2007: 742).
It also follows that unequal participation can lead to unequal decisions. Victims' failure to show up at sentencing and parole hearings can lead to unequal sentencing and parole decisions, because of the extraordinary discretionary power afforded judges and parole officers. The inequity is mitigated somewhat by determinate sentences, but in some sentencing, and most parole outcomes there is a risk of biased influence.
Test of Research in the Triangle Region
The Triangle is a region of North Carolina anchored by the cities of Raleigh, Durham and Chapel Hill, and respectively Wake, Durham and Orange counties. The region has a population of 1,111,755 as of March, 2007 . Each county’s district attorney’s office is responsible for some victim services and programs. The Wake district attorney serves the largest county and staffs a victim services program with twenty victim witness assistants. The Durham district attorney’s office has a victim assistant staff of thirteen, while Orange (the smallest county) has a district attorney’s office with three victim assistants.
Telephone interviews were conducted with all three district attorney offices. Interviewees were asked to comment on victim satisfaction in the use of victim impact statements, and whether the VIS tended to influence sentencing outcomes.
A victim witness assistant from Orange County with 15-years experience working with domestic violence and misdemeanors reported an approximate 50% response rate for written victim impact statements, though she mentioned some victims in these cases preferred to respond orally. In this worker’s experience the VIS was “a very effective tool in letting the victim’s voice be heard.” The worker reported that most victims experienced satisfaction simply because they wanted someone to listen what they had to say. In terms of sentencing outcomes, the worker’s experience was that the VIS did have an impact on sentencing, but that victims did not appear overly vengeful:
“[The victim] will say, I don’t want this person to do jail for this, and the judge will take into account what the victim says, whether they’d prefer drug or alcohol treatment. The majority don’t want anything negative to happen.”
In terms of any social class barriers and any obstacles to communicating clearly through the VIS, the worker said they did not observe any issues; some victims were more articulate than others, but all were capable of getting their message across.
Another victim assistant who works in the Orange County district attorney’s office also had a response rate of 50% and reported they had no idea why the rate was so low. This worker dealt primarily with domestic violence, personal injury and felony cases. The worker reported that in the case of rapes or homicides, “victims want to be heard and seen”, but in the case of property crimes that this was not the case. The worker reported that judges do listen to VISs, but because of structured sentencing in North Carolina, “I don’t think the victim impact statement has an impact on sentencing.”
Finally, an Orange County case worker who dealt primarily with misdemeanor assaults and property injuries reported a 90% response rate on victim impact statements, with a greater attention to severe cases. The worker reported a greater urgency to deliver the VIS orally, “in really bad assault cases”. The worker observed that many victims found it rewarding to tell their stories, and in cases where a family member was killed in a motor vehicle accident, “oral VISs tended to bring some closure to survivors.” This worker’s experience was that victims “just wanted to be heard”.
In the case of Wake County, it was stated that integrating victims into the criminal justice process was a major priority of District Attorney, Collin Willoughby. A victim witness assistant with Wake County reported an 85% return rate of victim impact statements. The worker stated that the process was “very letter based” because attorneys wanted complete files for all cases, and if the office did not receive a response to VIS, they would follow up with phone calls to the victim. The worker stated that victims appeared to experience satisfaction because, “they had a sense of validation in writing their experience down”. For property crimes, victims were unlikely to present orally, but in the case of homicide many did present orally. The worker did not think the VIS affected sentencing outcomes because so much about the process is worked out prior to the trial:
[The DA] would discuss plea bargain options and any maximum sentence possibilities with victims prior to the trial.
A victim witness assistant in the Durham County District Attorney’s office commented that the response rate to VISs was “very low”, and that the office had had specific meetings to focus on the problem. The worker commented that there were always problems with returned mail, or victims moving but that ultimately, “the effect of crime on a victim was hard”, and that probably attributed to the low response rate. An assistant district attorney (ADA) with the Durham courts followed up on the problem of low responses to VIS:
“… you’ll call and ask them why they haven’t returned it, they’ll say, 'I forgot, I didn’t receive it, I’ve been meaning to return it.' I think a lot of them are just embarrassed about what happened to them.”
The Durham ADA also stated she was surprised at the number of victims who did not want to participate in the process:
“… you would be surprised at how many don’t respond at all! They only want to know the end result, they don’t want the process information. And these are for white collar offenses like embezzlement. If it were me, I’d want to know it all.”
The Durham ADA commented that a lot of victims would ask the judge for sentencing outcomes, but the request was not always for a maximum sentence:
“A lot of them, like say in the case where a CNA (certified nursing assistant) embezzles from the elderly, the family will want to throw the book at them, but some victims are like good Samaritans, they’ll plead for a second chance, even though the judge wants to throw the book at them.”
The ADA commented that judges were definitely sensitive to victim requests. Because of structured sentencing, victims did not influence decisions of longer sentences, but in cases where victims asked for sentence reduction, that they could exercise influence.
In North Carolina parole is administered by the North Carolina Department of Correction. Though structured sentencing became effective in 1994 - essentially doing away with the parole function - North Carolina’s parole commission exists to grant discretionary release authority to those offenders sentenced under the pre-existing structure. The commission is served by three commissioners with power to grant release to offenders it deems are ready to re-enter society.
The executive assistant to the chairman of parole, Charles L. Mann, Sr. indicated that the board was well aware of the discretionary powers granted to them. Thus, the board is “sensitive to victim impact statements”, but the VIS is only one component of many factors that can influence parole decisions. In addition to victim input, the offender’s family is also invited to write or speak to the commission. The commission also considers offender behavior while under incarceration, the custody level of the offender, and comments from law enforcement, attorneys, and other participants in the justice system. As well, the offender must participate in the Mutual Agreement Parole Program (MAPP) designed to prepare offenders for release. In essence the MAPP is “a contract for release” between the offender, the Division of Prisons, and the Parole Commission. In summary the Chairman’s executive assistant stated that the commission does have discretionary powers, but theirs was “a complete and informed decision” on whether to grant parole privileges.
Discussion and Conclusion
Two often cited concerns of the use of victim impact statements during sentencing and parole hearings revolve around the issues of due process and discretionary bias. In sentencing, the solution to one problem may lie in the even administration of the other. If the courts move more toward determinate sentencing structures, VISs will no longer threaten to undermine the sentencing process. In one respect, the literature on VIS impact has sought solutions where there does not appear to be a problem. There is insufficient evidence to suggest victims want blood justice. If VISs demonstrate no influence on sentencing outcomes, then why do researchers continue to keep vigil over their potentially harmful influence? And what of victims who plead for mercy? In these cases, would not determinate sentencing block the courts from reaching an alternative, restorative solution? In one sense, a shorter sentence, or alternative form of punishment such as treatment would be better if it reduced pressures on the corrections process. However, it can be argued that since the justice system revolves around crimes committed by offenders against the state, the victim has no place in influencing the courts in any fashion, even if it is perceived to be for the benefit of society.
The issue of unfair influence on parole outcomes is more complex, and there is a need for further research in this area. Research has demonstrated that victim impact statements can exercise strong influence on parole decisions. From this perspective – and assuming the potential for a parolee to recidivate - perhaps a better question is not, can a victim’s voice reduce crime, but should it? Though researchers have cautioned to weigh VISs in the full contextual picture of the offender’s rehabilitation, there is not a lot of research that demonstrates parole boards are actually doing this. Certainly in jurisdictions where parole has been eliminated and offenders are made to fulfill their entire sentences, the VIS is less a threat. Where parole boards are permitted discretion in releasing or further incarcerating offenders, victim impact statements can bias parole outcomes, and we must ask ourselves, is this fair? Is it fair to an offender that he or she may draw a victim who is particularly vigilant and dedicated to be present and participate in all parole hearings, versus another victim who fails to show up? The counter argument to this question is to agree with William Rehnquist’s assertion that “…victim impact evidence is simply another form or method of informing.” If we are to follow Rehnquist, many aspects of the justice process are prejudicial. Not every offender gets to be represented by a legal “dream team”, some get what’s assigned to them; is this fair? It would appear unfair to silence one voice in the decision process – one voice among many factors – simply to arrive at a place of perceived equity, when ultimately the entire justice process is out-of-balance. The bottom line is that exclusion is everywhere.
These questions must ultimately be addressed by new research that will investigate further the true types of influence victim impact statements have on parole decisions, and whether any corrective policy measures need to be taken.
 Morgan, K., Smith, B.J., Victims, Punishment, And Parole: The Effect of Victim Participation On Parole Hearings. Criminology, volume 4 (2), page 336.
 Booth v. Maryland, 482 U.S. 496 (1987).
 South Carolina v. Gathers, 490 U.S. 805 (1989)
 Payne v.Tennessee, 501 U.S. 808 (1991)
 Walsh, A. (1986). Placebo Justice: Victim Recommendations And Offender Sentences in Sexual Assault Cases. The Journal of Criminal Law and Criminology, volume 77(4), page 1139.
 Ibid 3, 808.
 Erez, E., Tontodonato, P. (1990). The Effect of Victim Participation In Sentence Outcome. Criminology, volume 28(3)
 Ibid 6, 469
 Ibid 6, 469
 Young, A. (2001). The Role of the Victim in the Criminal Process. Policy Centre for Victims Issues, page 11.
 United States v. Booker, 543 U.S. 220 (2005)
 Marquart, J. W., (2005) Bringing Victims In, But How Far?. Criminology, volume 4 (2), page 330.
 McLeod, M. (1989) Getting free: Victim participation in parole board decisions. Criminal Justice, volume 4, pages 12-15.
 Parsonage, W. H., Bernat, F.P., Helfgott, J.(1992). Victim Impact Testimony and Pennsylvania’s Parole Decision Making Process: A Pilot Study. Criminal Justice Policy Review, volume 6(3)
 Ibid 1, page 333.
 Moriarty, L., J. (2005) Victim Participation At Parole Hearings: Balancing Victim, Offender, And Public Interest. Criminology, volume 4, (2) pages 387.
 Trulson, C., R. (2005) Victims’ Rights And Services: Eligibility, Exclusion, And Victim Worth. Criminology, volume 4 (2), page 410.
 Goodrum, S. (2007) Victims’ Rights, Victims’ Expectations, and Law Enforcement Workers’ Constraints in Cases of Murder, Law & Social Inquiry, Volume 32 (3) page 726.
 Skolnick, J. H. (1994) Justice Without Trial: Law Enforcement in Democratic Society, 3rd edition. New York: John Wiley & Sons.
 U.S. Department of Commerce, Bureau of Economic Analysis (www.bea.gov)
 Ibid 4.