Summary
The Violence Against Women Act in the United States celebrated its thirteenth anniversary in September 2024. Also in September, a female Olympian was violently murdered by her former boyfriend in Kenya. And a woman in France has been hailed a feminist hero amid the rape trial against fifty men. These significant events present an opportunity to examine the progress and shortcomings in combatting violence against women.
By: Catherine Colt, JHBL Staffer
Introduction
Nearly half of all women in the United States have reported incidents of sexual violence, physical violence or stalking by an intimate partner at some point in their lifetime.[1] Over 60% of these fifty-nine million women have also reported suffering from mental or emotional harm as a result of this violence.[2] Intimate partner violence, a form of gender-based violence, is violence directed against a person because of that person’s gender or violence that disproportionately affects a particular gender.[3] Violence against women is a human rights violation and encompasses all gender-based violence acts that may lead to physical, sexual, psychological, or economic harm or suffering to women.[4] Congress enacted the Violence Against Women Act (hereinafter VAWA) to establish and fund programs that combat domestic violence, sexual assault, dating violence, and stalking.[5] VAWA recently celebrated its thirtieth anniversary on September 13, 2024.[6] Within the same month, an Olympic athlete in Kenya was killed by her former boyfriend, and a woman in France is testifying against her former husband and the fifty men accused of raping her.[7] While VAWA is significant practically and symbolically in combatting violence against women, societal gender perceptions continue to hinder efforts to prevent gender-based violence.[8] The hindering of preventive efforts highlights the importance of addressing the psychological impact on survivors’ mental health.[9]
Background
When VAWA passed in the United States in 1994, it was the first federal legislation to recognize domestic violence and sexual assault as crimes, as well as provide federal resources to combat violence against women.[10] VAWA’s passage was a triumph for lobbying women’s groups because states were failing to address issues of violence against women.[11] VAWA can be reauthorized every five years, and each renewal has secured further protections and developed additional programs to better meet the needs of survivors.[12] Most recently, Congress passed the VAWA Reauthorization Act of 2022 with bipartisan support, which included grants for programs such as, Improving Criminal Justice Response to Sexual Assault, Domestic Violence, Dating Violence, as well as Stalking and Outreach and Services to Underserved Populations.[13] However, needs for trauma-informed training and comprehensive services to address mental health needs that result from victimization remain unmet in the United States.[14]
Similar to VAWA in the United States, the Government of Kenya has enacted a range of laws and stated its commitment to ending gender-based violence; however, violence against women is still rampant.[15] At least 500 women in Kenya were reported as victims of femicide just in the past seven years.[16] In fact, Africa had the highest rate of gender-based killings in 2022, with an estimate of 20,000 women killed on the continent that year.[17] In Kenya, Olympian Rebecca Cheptegei was set on fire with gasoline by a man she was previously in a relationship with.[18] Cheptegei sustained burns to eighty percent of her body, in addition to internal inhalation burns, leading to multi-organ failure which ultimately killed her on September 5, 2024.[19]
The killing of Cheptegei fueled renewed horror and outcry from women’s rights campaigns.[20] In January of 2024, thousands took to the streets in Kenya to protest gender-related violence and femicide, emphasizing women’s constant fear for their own safety just from being a woman.[21] While organizations support survivors of gender-based violence through mental health counseling and other aid, societal norms grounded in men’s entitlement and control over women are at the core of preventing progress.[22]
Similar to Kenya, numerous legislative initiatives in France have attempted to combat violence against women with limited success.[23] For example, Gisèle Pelicot has been in court this month in a rape trial against her former husband and fifty additional men.[24] Prosecutors say that for over a decade, Ms. Pelicot’s former husband repeatedly drugged and raped her, invited fifty other men to also rape her, and filmed the abuse.[25] The case has evoked horror in France, and Ms. Pelicot is hailed a feminist hero for waiving her right to anonymity in order to make the trial and the identities of the men public.[26] The trial has ignited discussions about how societal issues, such as toxic masculinity, perpetuate violence and French societal norms emphasizing sexual freedom disadvantage victims’ credibility.[27] Furthermore, the case has highlighted the importance of providing support for survivors and their mental health.[28]
Analysis
Amid these global atrocities, the thirtieth anniversary of the United States’ VAWA is an opportunity to recognize the successes of the act, but it also highlights just how much more still needs to be done to combat violence against women.[29] Intimate partner violence declined 53% from 1993-2008, suggesting VAWA’s passage played a crucial role.[30] Funding from VAWA supports evidence-based practices to effectively reduce violence over time, including educating and training professionals who respond to gender-based violence.[31] However, 5.7 million women in the United States endured intimate partner violence and experienced a physical, psychological, or economic harm within twelve months in a 2017 study.[32] The United States is not immune from societal perceptions and toxic masculinity which perpetuate gender-based violence globally.[33] VAWA acknowledges that effective community education can prevent violence against women by changing societal attitudes that legitimize it.[34] Such education can create societal awareness and ultimately mirror the societal perspective shift in France ignited by the horrors of the public fifty-person rape trial.[35] Therefore, creating awareness of the problematic nature of societal norms that perpetuate violence against women can attack gender-based violence at its roots.
Domestic abuse and sexual violence are associated with an increased risk of mental disorder.[36] Receiving trauma-informed, survivor-focused victim services, such a counseling, support groups, or advocacy, can result in lower rates of mental health struggles, self-blame, depression, and risk of revictimization.[37] VAWA recognizes the importance of instituting programs to address the psychological impact of gender-based violence on survivors.[38] However, there is insufficient availability of comprehensive victim services to address mental health needs of victims.[39] The victim services field is chronically under-resourced with limited budgets and high staff turnover, leaving thousands of victims’ requests for services unmet.[40] Victims’ mental health is crucial to preventing repeat victimization.[41] Therefore, directing sufficient resources to provide victims with the services they need is essential in combating violence against women.[42]
Conclusion
Global headlines include both the recent atrocities against women and the anniversary of VAWA. This contrast provides an opportunity to reflect on the progress and shortcomings in combatting violence against women. These news-worthy events are important to initiate conversation on the difficult topic and ultimately shift societal perspective on gender perceptions that perpetuate this violence. Hopefully this will lead to more successes to highlight at VAWA’s next decennial.
Disclaimer: The views expressed in this blog are the views of the author alone and do not represent the views of JHBL or Suffolk University Law School.
Catherine is a second-year JD/MSLL student at Suffolk University Law School with an interest in intellectual property, life sciences, and business. She received a bachelor’s degree in Economics with a minor in Spanish from the University of California, Los Angeles and a Master of Business Administration from the University of Nevada.
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[1] See Ruth W. Leemis et al., Ctr. for Disease Control & Prevention, The National Intimate Partner and Sexual Violence Survey: 2016/2017 Report on Intimate Partner Violence 1, 4 (Oct. 2022), https://www.cdc.gov/nisvs/documentation/NISVSReportonIPV_2022.pdf [https://perma.cc/UH9L-RSCR]
(reporting statistics from 2016-17 survey on intimate partner violence). In the United States, 47.3% or fifty-nine million women reported any contact sexual violence, physical violence, and/or stalking by an intimate partner at some point in their lifetime. Id. Contact sexual violence includes rape, sexual coercion, and/r unwanted sexual contact. Id.
[2] See id. at 12. Of the fifty-nine million women who reported any contact sexual violence, physical violence, and/or stalking by an intimate partner at some point in their lifetime, 86.8% also reported at least one impact related to intimate partner violence. Id. The impacts in the report included fear, concern for safety, PTSD symptoms, injury, need for services, and impact on work or school. Id. at 12, 32. For example, 71.3% of the female victims reported PTSD and 60.1% reported mental or emotional harm. Id.
[3] See What is gender-based violence?, Eur. Comm’n, https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/gender-equality/gender-based-violence/what-gender-based-violence [https://perma.cc/E4ZE-HTEW] (defining gender-based violence). Gender-based violence can take different forms and primarily affects women and girls. Id. While women and girls are the primary victims of gender-based violence, the effects permeate to harm families and communities. Id.
[4] See id. Gender-based violence can take on various forms, whether physical, sexual, or psychological abuse. Id.
[5] See Violence Against Women Act, 34 U.S.C. §§ 12291-12514 (1994); see also Violence Against Women Act, Nat’l Network to End Domestic Violence (2024), https://nnedv.org/content/violence-against-women-act [https://perma.cc/73UP-XMCX] (explaining history of VAWA).
[6] See Violence Against Women Act, 108 Stat. 1902 (1994) (codified at 34 U.S.C. §§ 12291-12514); see also Deputy Attorney General Lisa Monaco marks 30th anniversary of Violence Against Women Act, Legal Newsline (Sept. 13, 2024) https://legalnewsline.com/stories/664272492-deputy-attorney-general-lisa-monaco-marks-30th-anniversary-of-violence-against-women-act [https://perma.cc/3NBW-TZJH] (recapping deputy attorney general’s remarks on VAWA anniversary); Justice official reflects on three decades since Violence Against Women Act, Legal Newsline(Sept. 13, 2024) https://legalnewsline.com/stories/664272473-justice-official-reflects-on-three-decades-since-violence-against-women-act [https://perma.cc/F9XJ-TNBB] (recapping Principal Deputy Associate Attorney General’s remarks on VAWA anniversary); Justice Department announces $690 Million in Violence Against Women Act funding, Wis. L. J. (Sept. 13, 2024) https://wislawjournal.com/2024/09/13/justice-department-announces-690-million-in-violence-against-women-act-funding/ [https://perma.cc/QF2A-LJ9K] (detailing funding announcing commemorating VAWA anniversary).
[7] See Isabella Kwai & John Yoon, Rebecca Cheptegei, Olympic Runner From Uganda, Dies After Gasoline Attack, N.Y. Times (Sept. 5, 2024), https://www.nytimes.com/2024/09/05/sports/rebecca-cheptegei-dead-uganda-olympic-athlete.html [https://perma.cc/5249-CMUY] (reporting killing of Rebecca Cheptegei). Cheptegei competed in the women’s marathon at the Paris Olympics before a man she was previously in a relationship with killed her a month later. Id. The man attacked Cheptegei with gasoline and set her on fire on September 1, 2024. Id. Cheptegei sustained burns to eighty percent of her body and died in an intensive care unit four days later from multiple organ failure. Id. Officials stated the man responsible would be charged with murder. Id. See Catherine Porter & Ségolène Le Stradic, France’s Horrifying Rape Trial Has a Feminist Hero, N.Y. Times (Sept. 25, 2024), https://www.nytimes.com/2024/09/25/world/europe/france-rape-trial-gisele-pelicot.html [https://perma.cc/E6X2-K268] (reporting on Gisèle Pelicot’s trial against fifty-one men accused of raping her). Gisèle Pelicot’s former husband of fifty years pleaded guilty to drugging her food and drinks for almost a decade and inviting men into their bedroom to join him in raping her while she was drugged. Id. Her ex-husband and most of the additional fifty male defendants are charged with aggravated rape. Id. More than a dozen of the male defendants have pleaded guilty to rape. Id. Most of the remaining defendants do not dispute they had sex with Ms. Pelicot but claim it was not rape because they believe it was consensual or they were tricked into believing it was consensual. Id. This trial is unusual for rape trials because many of the encounters are documented by graphic video and photo evidence. Id.
[8] See Off. on Violence Against Women, U.S. Dep’t Just., The 2022 Biennial Report to Congress on the Effectiveness of the Grant Funds Under the Violence Against Women Act at viii (2024), https://www.vawamei.org/wp-content/uploads/2024/05/2022-Biennial-Report-to-Congress_FINAL.pdf [https://perma.cc/TF33-CR2D] (providing overview of VAWA effectiveness). VAWA aims to ultimately achieve the goal of a society that is intolerant of violence against women. Id. at 2.
[9] See id. at 21. VAWA grantees report mental health victim services needs are unmet. Id. The impacts of COVID-19 have increased the rates at which survivors are experiencing mental health crises. Id. at 22.
[10] See Violence Against Women Act, 108 Stat. 1902 (1994) (codified at 34 U.S.C. §§ 12291-12514); see also Nat’l Network to End Domestic Violence, supra note 5. Then-Senator Joe Biden authored the original VAWA, passed in 1994. Id.; History of VAWA, Legal Momentum: Women’s Legal Def. & Edu. Fund, https://www.legalmomentum.org/history-vawa [https://perma.cc/QZ28-MAY7]. The 1994 VAWA of 1994 included provisions on rape and violence, focusing on prevention funding for victim services and evidentiary matters. Id. The VAWA of 1994 also included the first federal criminal law against battering. Id.
[11] See Legal Momentum: Women’s Legal Def. & Edu. Fund, supra note 10.
[12] See Violence Against Women Act of 2000, 114 Stat. 1491 (2000) (codified as amended at 34 U.S.C. §§ 12291-12514); Violence Against Women and Department of Justice Reauthorization Act of 2005, 119 Stat. 2960 (2005) (codified as amended at 34 U.S.C. §§ 12291-12514); Violence Against Women Reauthorization Act of 2013, 127 Stat. 54 (2013) (codified as amended at 34 U.S.C. §§ 12291-12514); see also Nat’l Network to End Domestic Violence, supra note 5. The first VAWA reauthorization in 2000 created legal assistance programs to meet the needs of victims and further added provisions for dating violence and stalking. Nat’l Network to End Domestic Violence, supra note 5. The 2005 reauthorization also adjusted to meet the needs of survivors with new, holistic responses and programs, such as finding for rape crisis centers. Id. In 2013, the reauthorization expanded to provide access to safety and justice to disadvantaged groups, such as immigrants, Native Americans, LGBTQ+, and public housing residents, as well as college students and youth. Id.; Legal Momentum: Women’s Legal Def. & Edu. Fund, supranote 10.
[13] See Violence Against Women Reauthorization Act of 2022, 136 Stat. 840-962 (2022) (codified as amended at 34 U.S.C. §§ 12291-12514); see also Off. on Violence Against Women, supra note 8, at 4-5 (reporting findings on current VAWA effectiveness); Nat’l Network to End Domestic Violence, supra note 5. The VAWA Reauthorization Act of 2022 includes provisions to strengthen and modernize the law. Nat’l Network to End Domestic Violence, supra note 5. The provisions include funding and resources for community programs as well as new economic justice provisions, intended to strengthen non-discrimination laws. Id.
[14] See Off. on Violence Against Women, supra note 8, at xii. VAWA grantees/subgrantees and state administrators are regularly asked to identify unmet needs in their community to aid the Office on Violence Against Women’s understanding of areas in need of improvement, under-resourced issues and gaps in services. Id. The report includes a list of critical areas of unmet needs identified by grantees and state administrators. Id.
[15] See Femicide cases in Kenya fuel urgent calls for action to end violence against women, UN Women (Feb. 9, 2024), https://www.unwomen.org/en/news-stories/feature-story/2024/02/femicide-cases-in-kenya-fuel-urgent-calls-for-action-to-end-violence-against-women [https://perma.cc/R78Z-WWGJ] (reporting on protests and reactions to femicide in Kenya). Kenya has a robust legal framework of laws relating to gender-based violence, but enforcement of such laws is lacking. Id. The Government of Kenya has committed to ending gender-based violence by 2026. Id.
[16] See Silencing Women: Tracking Femicide Cases reported in Kenyan Newspapers, Afr. Data Hub (2024), https://www.africadatahub.org/femicide-kenya [https://perma.cc/F3BL-RSCA] (tracking femicide cases reported in Kenyan Newspapers from 2016 to date). “Femicide is the killing of women and girls with gender-related motivations and is the most extreme form of gender violence on women.” Id.; see also Kwai & Yoon supra note 7. Among these deaths include two other professional athletes, Agnes Jebet Tirop whose husband stabbed her to death in 2021 and Damaris Muthee Mutua whose husband strangled her to death in 2022. Kwai & Yoon supra note 7; Fred Kibor, Autopsy reveals how athlete Damaris Mutua died, Nation (Apr. 22, 2022), https://nation.africa/kenya/sports/athletics/athlete-damaris-mutua-was-strangled-exam-reveals-3790088 [https://perma.cc/935R-6YND] (reporting Damaris Muthee Mutua’s killing). Kenyan-Bahraini professional athlete Damaris Muthee Mutua’s male partner strangled her to death in 2022. Kibor, supra; Abdi Latif Dahir, Kenyan Olympian’s Killing Exposes Surge of Violence Against Women, N.Y. Times (Oct. 24, 2021), https://www.nytimes.com/2021/10/24/world/africa/agnes-jebet-tirop-stabbing-arrest.html [https://perma.cc/W9TS-QALD] (reporting Agnes Jebet Tirop’s killing and reaction). Tirop competed in the Tokyo Olympics in the summer of 2021 before her husband stabbed her to death the following October. Dahir, supra. Her killing ignited a conversation in Kenya about the persistent problem of violence against women. Id.
[17] See Gender-Related Killings of Women and Girls: Global Estimates of Female Intimate-Partner/Family-Related Homicides in 2022, United Nations (2023), https://www.unwomen.org/sites/default/files/2023-11/gender-related-killings-of-women-and-girls-femicide-feminicide-global-estimates-2022-en.pdf [https://perma.cc/5MC6-M323] (reporting global findings regarding gender-related violence). The estimate of 20,000 victims in 2022, while subject to some uncertainty due to limited data and lack of reporting, brings Africa to surpass Asia for the first time in female intimate partner killings. Id.
[18] See Kwai & Yoon, supra note 7. Cheptegei competed in the women’s marathon at the 2024 Paris Olympics. Id. The following month she was killed by a previous romantic partner. Id.
[19] See id.; Anne Soy & Damian Zane, Thousands mourn Ugandan Olympian killed by ex-partner, Brit. Broad. Corp. (Sept. 14, 2024), https://www.bbc.com/news/articles/c0494wl6lkgo [https://perma.cc/L9CT-U7LM] (reporting killing of Cheptegei and public reaction).
[20] See Kwai & Yoon, supra note 7; Soy & Zane, supra.
[21] See UN Women, supra note 15. On January 27, 2024, thousands of women and men marched in major cities in Kenya for an end to violence against women. Id.
[22] See id. UN Women leads initiatives aiming to prevent gender-based violence in Kenya, such as providing specialized training to police. Id. However, societal perceptions that normalize the killings and victim blaming need to change to put an end to gender-based violence. Id.; see also Soy & Zane, supra note 19. Female athletes are particularly vulnerable to gender-based violence due to their independence and specifically financial independence that contradict traditional gender norms. Soy & Zane, supra note 19; United Nations, supra note 17.
[23] See Anthony Bulger, The Problem of Violence against Women in France, Fr.-Amerique (Mar. 10, 2023), https://france-amerique.com/the-problem-of-violence-against-women-in-france [https://perma.cc/SCA4-UNFB] (reporting persistence of violence in France). President Emmanuel Macron announced violence against women as one of his government’s major national causes when he came to office in 2017. Id. At that time, the global #MeToo movement and local #BalanceTonPorc (“Squeal on your pig”) were at their height, urging Macron’s administration to act. Id. The administration produced forty-six measures in 2019, including specialized training for law enforcement and emergency accommodation. Id. However, femicide claimed the lives of 122 women in France in 2021. Id.
[24] See Ségolène Le Stradic & Catherine Porter, The Rape Trial in France of 51 Men, Explained, N.Y. Times (Sept. 18, 2024), https://www.nytimes.com/article/french-rape-trial-51-men-dominique-pelicot.html [https://perma.cc/H6ZM-SQ2P] (explaining details of Pelicot’s trial); Porter & Le Stradic, supra note 7.
[25] See Porter & Le Stradic, supra note 7; Le Stradic & Porter, supra. Ms. Pelicot’s former husband has pleaded guilty to all charges against him, including drugging and aggravated rape. Id.
[26] See Porter & Le Stradic, supra note 7. Ms. Pelicot’s trial has gained much attention in France due to both the horrific nature of the case and Ms. Pelicot’s decision to waive her right to anonymity. Id. Ms. Pelicot did this so the defendants’ identities would also be public. Id. Her supporters lined up outside the courtroom and applauded her courage in taking control of the narrative and shifting the blame and shame from victims to the perpetrators. Id. The legal defense, however, attempted to undermine her credibility by insinuating that she consented to the acts or had a “secret inclination for exhibitionism.” Id. Of the 20,000 photographs and videos found on her former husband’s devices, graphic images of Ms. Pelicot were shown in court, but the images revealing the male defendants would not be viewed publicly as to not “impugn the dignity of the men involved.” Id.
[27] See id. At the beginning of trial, Ms. Pelicot’s lawyers stated, “shame must change sides, from the victim to the accused.” Id. This phrase has become a mantra among Ms. Pelicot’s supporters. Id. Furthermore, the “normal” profiles of the male defendants–ranging in age from twenty-six to seventy-four with varied in occupations from salesmen to tech specialists–publicly “[skewer] the myth of the monster rapist.” Id. As a result, the trial has inspired soul-searching in France about gender norms and led to men discussing topic such as “rape culture” and “toxic masculinity.” Id. Ultimately, the trial has spiked awareness in the male population about the issue of gender-related violence. Id.; see also Bulger, supra note 23. Despite progress on women’s rights, sexism is not decreasing in France, and some of its “most violent manifestations are getting worse.” Id. See generally Kevin Foss, What is Toxic Masculinity and How it Impacts Mental Health, Anxiety & Depression Ass’n Am.(Nov. 14, 2022), https://adaa.org/learn-from-us/from-the-experts/blog-posts/consumer/what-toxic-masculinity-and-how-it-impacts-mental [https://perma.cc/C6RF-5QBW] (defining toxic masculinity).
[28] See Gisele Pelicot: Mental Health of French Mass Rape Victim, Calm & Caring Psych. (Sept. 15, 2024), https://calmandcaring.com/child-psychologist/f/gisele-pelicot-mental-health-of-french-mass-rape-victim [https://perma.cc/7CXA-3L8M] (addressing mental health implications of sexual violence). Ms. Pelicot’s bravery, despite her immense psychological trauma, has raised awareness about gender-based violence, and drug-induced sexual assault, specifically. Id. Survivors like Ms. Pelicot often face severe psychological impacts, such as PTSD, anxiety, depression, and dissociative disorders. Id. Women’s rights advocates assert that in addition to prosecution of the offenders, legal reforms must further provide social and psychological support for victims of gender-based violence. Id.
[29] See Violence Against Women Act, 34 U.S.C. §§ 12291-12514 (2022).
[30] See Monica Modi et al., The Role of Violence Against Women Act in Addressing Intimate Partner Violence: A Public Health Issue, 23 J. Women’s Health 253, 254 (Mar. 1, 2014), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3952594/#B4 [https://perma.cc/PU8Q-NM2J] (analyzing intimate partner violence and public health). From 1993 to 2008, the rate of intimate partner violence against women fell from 9.4 to 4.3 victimizations per 1,000 females aged twelve or older. Id.
[31] See Off. on Violence Against Women, supra note 8, at vi-x. The evidence-based practices are grounded in established and emerging research on national best practices to respond to domestic/sexual violence. Id.
[32] See Leemis et al., supra note 1, at 10. The reported harms to the victim include fear, concern for safety, PTSD symptoms, injury, need for services, and impact on work or school. Id.
[33] See Foss, supra note 27 (defining toxic masculinity and its effects). Toxic masculinity is “the way men are culturally trained and socially pressured to behave,” and its “three core tenants, toughness, anti-femininity, and power . . . combine to create the sense of ‘manliness.’” Id. Societal pressures for men to embody these traits perpetuates harmful attitudes and behavior towards women. Id.
[34] See Off. on Violence Against Women, supra note 8, at x. For example, bystander intervention programming at schools can change behavior and reduce sexual assault and dating violence. Id. Community education is crucial to achieve long-term reductions in violence against women by changing societal attitudes that legitimize such violent behavior. Id. at 52.
[35] See Porter & Le Stradic, supra note 7 (discussing public reaction to Pelicot’s trial).
[36] See Sian Oram et al., Violence Against Women and Mental Health, Lancet Psychiatry (Feb. 2017), https://prevention-collaborative.org/wp-content/uploads/2021/08/Oram_2017_Mental_health_violence_against_women.pdf [https://perma.cc/9HGY-FCLF] (discussing mental health implications of violence against women). Despite the clinical guidance that mental health services could have a major role in primary and secondary prevention of violence against women, little research has been done to improve mental health services for victims. Id.
[37] See Off. on Violence Against Women, supra note 8, at 11. Receiving victim services addressing mental health has been shown to improve both short- and long-term outcomes for victims. Id.
[38] See id.; see also Modi et al., supra note 30, at 256 (proposing further solutions).
[39] See Off. on Violence Against Women, supra note 8, at 12.
[40] See id. In 2021, the annual Domestic Violence Counts survey found that in a single twenty-four-hour period, victims made at least 12,500 requests for services that could not be met, because programs did not have the resources to provide these services. Id.
[41] See id.
[42] See id.