Why Medical Mandated Reporting of Domestic Violence Still Matters

This article originally ran in Domestic Violence Report Vol 29, No. 1 for October/November 2023. It is being reprinted with permission from the authors.

“I grew up with domestic violence. I lived with it for many years. And I almost lost my life to it,” Isabel said to a reporter in San Diego in July 2023 in the midst of a debate in California about a bill seeking to repeal medical mandated reporting of domestic violence by healthcare professionals. Isabel was in an abusive relationship for 15 years. The violence escalated to include strangulation and her husband managed to avoid consequences for his abuse throughout their relationship. Isabel was too scared to report his abuse and says she never would have been able to “press charges” herself. Ultimately, in January of 2018, Isabel’s husband grabbed a knife, threatening to kill her. She ran into her children’s room thinking he would not stab her in front of her kids. But he did. He stabbed her in the neck and her neighbors heard the fight and called the police. Paramedics came and kept her alive as they rushed her to the hospital. She was not able to speak but when doctors asked her who did this to her, she pointed at her husband who was in the next room being treated himself (for superficial, self-inflicted knife wounds).

Under California’s Suspicious Injury Reporting Law (Penal Code § 11160 et. seq.), police officers were notified, and her husband was arrested and prosecuted for felony domestic violence. Isabel was not able to “press charges'' or authorize a report to law enforcement the day she almost died. She was terrified and seriously injured. She needed doctors and nurses to follow California’s Medical Mandated Reporting Law and “do their job.” In Isabel’s words, “When they did their job, they saved my life.” 1

Few topics garner a more visceral reaction in the domestic violence and sexual assault movements than the issue of medical mandated reporting by medical professionals. Advocates and professionals who support reporting argue that it provides for early intervention before serious injury or death even if the victim is too injured or terrified to make a report. Those who oppose mandated reporting argue that some victims do not want doctors and nurses to report their abusers and therefore may not seek needed medical attention. Proponents of reporting argue reporting is homicide prevention. Opponents argue that mandated reporting violates “victim autonomy.” There is validity to the arguments on both sides of the debate. The question becomes how to make the public policy decisions about mandated reporting particularly when there is a split on this issue among professionals working in the violence prevention movement.

Medical mandated reporting of domestic violence currently exists in almost all states with varying levels of reporting required. Some states specifically use the term “domestic violence” while other states encompass domestic violence by using other terminology or include domestic violence under other types of crimes and injuries. One state, Kentucky, eliminated medical mandatory reporting to the Cabinet for Family and Children’s Services in 2017 with very mixed and debatable results 2. We argue that it is part of the cause for Kentucky’s large increase in domestic violence homicides since 2017. Others argue that Kentucky has made healthcare access easier for victims of domestic violence by ending all mandated reporting and offering voluntary referrals to services. Some states have updated their laws in the last five years, including Colorado 3, Tennessee 4 and Ohio 5. But they have each maintained medical mandated reporting for certain types of offenses (Colorado: “serious bodily injury”; Tennessee: “serious bodily injury”; and Ohio: “all  felony offenses producing injury”). 

California’s Medical Mandated Reporting Requirement

California has had one of the most specific medical mandated reporting laws on domestic violence in the country since 1994 6. Penal Code § 11160 requires a health care practitioner who treats a person brought into a healthcare facility or clinic who is suffering from specified injuries to report that fact immediately, by telephone and in writing, to the local law enforcement authorities. The duty to report extends to physicians and surgeons, psychiatrists, psychologists, dentists, medical residents, interns, podiatrists, chiropractors, licensed nurses, dental hygienists, optometrists, marriage and family therapists, clinical social workers, professional clinical counselors, emergency medical technicians, paramedics, and others. The duty to report is triggered when a health practitioner knows or reasonably suspects that the patient is suffering from a wound or other physical injury that is the result of assaultive or abusive conduct caused by another person, or when there is a gunshot wound or injury regardless of whether it self-inflicted or one caused by another person. Health practitioners are required to report if these triggering conditions are met, regardless of patient consent. Failure to make the required report is a misdemeanor.

California’s law has been criticized by some as too broad while supporters argue that mandated reports provide documentation of the violence of an abuser and the injuries they cause and ensure that a victim can connect with an advocate or other social services once local law enforcement receives the mandated report. In 2022, Futures Without Violence (Futures) and the California Partnership to End Domestic Violence (CPEDV) sponsored AB 2790 (Wicks) 7 to repeal California’s long-standing Suspicious Injury Reporting Law. They gathered a significant number of organizations in support of the bill, making representations about the views of survivors, seeking legislative findings on the detrimental impacts of reporting to survivor health and healthcare, and initially representing that there was “consensus” on the need to end reporting in the domestic violence movement. AB 2790 sought to eliminate the duty of healthcare practitioners to report known or suspected assaultive or abusive conduct and instead provide that they should, whenever medically possible, provide the person with “brief counseling”, a “warm handoff”, or a referral to local domestic violence services. 

AB 2790 sought to:

1. Limit a health practitioner’s duty to make a report of injuries to law enforcement to instances where: the injury is by a firearm, either self-inflicted or not; the wound or physical injury was the result of child abuse; or where the wound or physical injury was the result of elder abuse; 

2. Require health care practitioners who, in their professional capacity or within the scope of their employment, know or reasonably suspect that their patient is experiencing any form of domestic violence or sexual violence, to provide brief counseling and offer a referral to domestic violence or sexual violence advocacy services;

3. Provide that the health practitioner shall have met the requirement when the brief counseling, education, or other support is provided and a warm hand off or referral is offered by a member of the health care team;

4. Provide that, if the health practitioner is providing medical services to the patient in the emergency department of a hospital, the practitioner shall also offer assistance to the patient in accessing a forensic evidentiary exam or reporting to law enforcement, if the patient wants to pursue these options;

5. Allow the health practitioner to offer a warm hand off and referral to other available services including legal aid and community-based services;

6. Provide that, to the extent possible, health practitioners must document all nonaccidental violent injuries and incidents of abuse in the medical record 8.

Alliance for HOPE International, the California Sexual Assault Forensic Nurse Examiners Association, the Academy of Forensic Nursing, the California District Attorneys Association, the California Police Chiefs Association, the VOICES Survivor Advocacy Network, the Training Institute on Strangulation Prevention and many others sought to negotiate a compromise to ending virtually all mandated reporting but Futures, CPEDV, and the bill’s author, Assemblymember Buffy Wicks, were not willing to allow any mandated reporting to remain except for injuries resulting from gunshot wounds. AB 2790 passed through the Assembly but failed to move forward in the Senate. Once the bill failed, our opposition coalition sought to negotiate a compromise, consensus bill. This effort failed. Proponents of the bill would not agree to continue mandated reporting of “serious bodily injury” and would not support funding for bedside advocacy in the bill.

In 2023, Futures and CPEDV brought the same bill forward again, and California Assemblymember Tina McKinnor introduced it as AB 1028 9. The same organizations joined in support and opposition to AB 1028 as they had done with AB 2790. The California Board of Registered Nursing also came out unanimously against the bill in 2023; however, most healthcare organizations in California remained neutral on the bill. All efforts by our opposition coalition to find a compromise with the proponents of AB 1028 failed. On September 1, 2023, AB 1028 was held in committee and therefore failed. While our opposition coalition successfully stopped the repeal of California’s Suspicious Injury Reporting Law for the second time in two years, it saddens us that we could not find a compromise. 

We strongly support medical mandated reporting of domestic violence to law enforcement agencies (and/or Family Justice Centers) and bedside advocacy for seriously injured, high-risk victims of domestic violence. We do not support voluntary referrals as the only action of medical professionals. We do not support putting all responsibility on the victim for reporting the abuser and the injuries caused, particularly with seriously injured, high-risk victims such as strangled victims with traumatic brain injury. The core arguments against the repeal of medical mandated reporting of domestic violence in California are going to be relevant in debates across the country in the years ahead. We believe mandated reporting increases accountability for offenders and provides a greater likelihood of direct advocacy for victims.

Arguments and Responses

We enumerate here the arguments propounded by our opposition coalition in California during our recent debate with deference and respect to those who sought and may still seek to end medical mandated reporting of domestic violence, child abuse, elder abuse, human trafficking, or dependent adult abuse:

• Repealing California’s Suspicious Injury Reporting law would have been a major public policy change that was proposed by AB 2790 and AB 1028 without any recent research in California and without any evidence that replacing mandated reporting with voluntary referrals would increase safety or health outcomes for survivors. In fact, research provided by Highland Hospital in Alameda County, California, found that voluntary referral does not increase patient safety and does not connect victims to services. The research from Highland Hospital in Alameda County, California shows clearly that giving victims a “referral” or a piece of paper (which is what AB 1028 would become in busy trauma centers) only connects six percent of them to actual services. Using reporting to connect survivors to professionals at the Alameda County Family Justice Center, connected 50 percent of the survivors to actual advocacy and support 10. Proponents seeking the end of mandated reporting point to only one “study” to claim 83 percent of victims oppose medical mandated reporting. However, this “study” is not in any way connected to medical mandated reporting. Rather, it was data gathered in a “Chat Box” on the National Domestic Violence Hotline in 2015 and had nothing to do with reporting by doctors and nurses. The Chat Box was anonymous, and no questions were asked about California’s Suspicious Injury Reporting Law 11.
  
  
• Putting all responsibility for reporting on victims (in the name of “victim autonomy”), will take us back to the day when the criminal justice system would not intervene in domestic violence unless the victim wanted to “press charges.” Assemblymember Tina McKinnor, the author of AB 1028, even used that very phrase in a KPBS story on AB 1028 in San Diego. Assemblymember McKinnor said victims can “press charges” if they want their abuser to be reported 12. This approach would take us back 30 years in California to a day when victims had to “press charges” for abusers to face any accountability.
  
  
• The only survey done of survivors and advocates in California about AB 1028 was done by www.DomesticShelters.org in March 2023 at the request of Alliance for HOPE International. The survey questions were created by members of the VOICES Survivor Advocacy Network connected to California Family Justice Centers. The survey findings, distributed to all members of the Legislature, found that 76 percent of advocates and survivors in California support the existing Suspicious Injury Reporting Law. The survey found that if reporting was limited by a revised law, 83 percent of survivors and advocates in California still believe medical mandated reporting by doctors and nurses should continue for “serious bodily injury cases” including stabbings, strangulation, and other major injury cases. Finally, the survey found that 98 percent of survivors and advocates believe that if mandated reporting is eliminated, advocates should be funded to come to the bedside of high risk, seriously injured victims of domestic violence to provide support and resources 13. In short, this means that the proponents of AB 1028 were not representing the views of California survivors and their “research” was not supported by any California-based data. 
  
  
• In their advocacy for ending mandated reporting, proponents have said that only three states have medical mandated reporting for domestic violence. On the contrary, 45 states have reporting for different levels of domestic violence. Numerous organizations have done studies of these reporting laws across the country 14. But in 2023, Alliance for HOPE International CEO Gael Strack conducted a fresh analysis of all 50 states and posted those findings on the Legislation Map on the website for the Training Institute on Strangulation Prevention 15. Her findings are critical to the debate.
  
  Gael Strack found the least amount of reporting occurs in the states with the highest domestic violence homicide rates in the country; for example, Alabama, New Mexico, Wyoming, and Puerto Rico have no reporting laws. While Alabama does not share their homicide statistics with the Violence Policy Center, then Executive Director Alison Dearing of One Place Metro Alabama Family Justice Center reported that domestic violence homicides had reached historic levels in Birmingham, Alabama 16. In the Violence Policy Center’s 2022 annual report: “When Men Murder Women,” New Mexico ranked No. 12 and Wyoming ranked No. 3 of the states with the highest female homicides 17. In 2021, Puerto Rico’s Governor, Pedro Pierluisi, declared a state of emergency in Puerto Rico due to gender violence and the high rates of domestic violence homicides 18.
  
  
• Kentucky, the only state to repeal mandatory reporting of domestic violence since 2017, has seen an increase of more than 100 percent in domestic violence homicides. While the causes of increased domestic violence homicides are complex to analyze, there has been no analysis of how ending reporting may have reduced consequences for dangerous offenders and therefore potentially increased homicides. Kentucky now ranks #8 in States of Women Murdered in the U.S. 19.  More importantly, with the exception of Delaware, the states that only have mandated reporting of gunshot wounds (as proposed in AB 2790 and AB 1028) are all in the Top 10 states where the most women are murdered by men 20.
  
  
• The proponents offer a few anecdotes but no research to support their claim that women do not access health care when needed because of medical reporting. Opponents of AB 1028, on the other hand, have anecdotes of women who say that mandated reporting saved their lives as well 21. We cannot pass laws based on anecdotes. We should pass laws based on research, hard evidence, and on what those working in the field believe will work. The “field,” (that is, advocates and survivors), appear to believe current law is appropriate and a pathway to support and services. The “field” also supports maintaining medical reporting for “serious bodily injury” including strangulation, stabbings, and major violence that causes brain damage. 
  
  
• Today, in California and across the country we are asking, “Who is most dangerous to the public? Who poses threats to vulnerable people? Who presents the greatest risk of being a mass shooter?” In response, we are passing “red flag” laws. We are promoting, “See Something, Say Something.” The research is clear that men who strangle women are more likely to later kill them. If a woman is strangled one time by a man, she is 750 percent more likely to later be killed by him 22. We have learned that men who commit domestic violence (including strangling women) represent the majority of mass shooters in the country 23. We have learned that the majority of police officers killed in the line of duty are killed by men who have previously strangled a woman in a domestic violence assault 24. If AB 1028 had passed, we would not have been able to keep reporting stranglers in California and the injuries they cause because we would make victims (including terrified, seriously injured victims of stranglers) “press charges” before doctors and nurses can report the abuser or the injuries he causes (or medical professionals risk a violation of HIPAA and a lawsuit). We would have needed to explain why you cannot report under HIPAA without a law that authorizes it.
  
  
• Proponents claim that ending reporting is the national trend. But the last three states to address medical mandated reporting (Tennessee, Colorado, and Ohio) all kept reporting for serious cases. Tennessee maintained reporting for “Serious bodily injury,” including strangulation. Colorado maintained “Serious bodily injury” and then strangulation was ruled “serious bodily injury” by a Colorado appellate court in People v. Bowers, 491 P.3d 400 (Colo. 2021), adding it to the list. And Ohio just made all felonies producing injury, including strangulation, a mandated report by doctors and nurses. Only Kentucky has banned all reporting and has seen a massive increase in domestic violence homicides 25.
  
  
• Researchers in Australia and New Zealand have identified a concept called “professional dangerousness” which addresses when health professionals take or fail to take certain action and thus health professionals put the victims in more danger by their actions. AB 1028 will produce “professional dangerousness” by the inability of doctors and nurses to report in California 26. 
  
  
• The University of Iowa Study (2010) determined the cost of one homicide is $17 million when all system and economic costs are included. If ending reporting of domestic violence increases domestic violence homicides in California, the cost will run into the tens of millions of dollars along with the moral outrage of such a consequence 27.
  
  
• Researchers in a 2014 study that focused on the relationship between women’s risk of homicide as measured by the Danger Assessment and 13 protective actions, found that while calling law enforcement may have mixed results, at least one study relying on victim self-report found that self-report was a protective measure by 74.8 percent 28.
  
  
• If AB 1028 had passed, high-risk, seriously injured victims would have been asked if they are willing to report their abuser and the injuries he caused. If the victim said “no,” there would have been no report to police, an advocate, a social worker, a shelter, or a Family Justice Center. The result: Women would have died at higher rates in California. The real-life scenarios we have witnessed during our careers, and how they would have played out had AB 1028 passed are stunning. For example:
  

  
  A high-risk victim walks into a hospital emergency room with a knife sticking out of her chest. She says her boyfriend stabbed her and she is terrified he will find her and kill her — so she does not to call the police. Had AB 1028 passed, the hospital could not have called law enforcement to ensure accountability for the offender or report the injuries he has inflicted.

  A victim is transported by ambulance after having a stroke. She has suffered major brain injury. At the hospital she discloses that she was strangled a day earlier by her husband when he told her that if she talked to police, he would kill her. She feels she cannot call the police based on his threats. Had AB 1028 passed, the assault would not have been reported. 

  A pregnant woman six months into her pregnancy is repeatedly kicked in the stomach and loses her baby. She goes to the hospital and discloses the identity of her abuser, but she is too terrified and confused to have to be responsible for reporting to the police. Had AB 1028 passed, there would not have been law enforcement intervention with the abuser or safety services offered to her other than a “referral” and “brief counseling.” 

  A victim seeks medical attention for her injuries from domestic violence. She reports she was in a car accident. Due to the type of injuries, the medical provider becomes suspicious and questions her about her car. The victim admits she does not have a car and it was her abuser who told her to lie to the doctor. Although the doctor is concerned for her safety, had AB 1028 passed, the doctor would have had no responsibility to do anything to increase her safety or the offender’s accountability.  

• Survivors opposing this bill have made many compelling arguments in legislative hearings in Sacramento. They include:

• Survivors like us have not been asked our opinion in the rushed effort by supporters of this bill to push it through the California Legislature. We support doctors and nurses, and we believe the the majority of survivors, like us, support doctors and nurses reporting serious domestic violence when victims are too injured and/or too scared to take that responsibility themselves."

• Supporters of the bill are saying that by ending reporting, they are honoring “victim autonomy.” When victims of domestic violence are experiencing violence, verbal abuse, emotional abuse, even sexual abuse by their partners, they do not have “autonomy.” Pretending that you are giving us our power back in a split second while we are being treated for serious and even life-threatening injuries, makes no sense.

• The only national survey we know of, done by Dr. Jackie Campbell (who supports keeping medical mandated reporting in California for “serious bodily injury”) says that the majority of domestic violence survivors support reporting (59 perfect) (Sachs, et al, 2008).29 Why have proponents not done a new survey in California? Why have they not done focus groups with diverse groups of survivors like us? The wwwDomesticShelters.org  survey in March 2023 shows the majority of survivors support reporting.

• This bill was rushed through for the second year in a row with very little input from thousands of us across California who have lived the terror and fear of domestic violence and the “research” has been manipulated. Do some victims fear reporting to medical professionals? Yes. They also fear reporting to friends, family, ministers, counselors, employers, and others. They mostly fear their abuser. When you live in constant fear, you fear the consequences for everything when your abuser is controlling your life and threatening to kill you if you tell anyone. This bill would not have solved that problem because doctors and nurses would have had different policies all over the state. Victims would still have been in fear because they would not know what the policies are in their county or city. Why rush a bill when you do not know what will happen?

• Victims of domestic violence in California deserve the best services possible when they come forward for help. But this bill has no services, no funding, and no training to improve services or increase what we call trauma-informed approaches for survivors.




Conclusion

The Training Institute on Strangulation Prevention is currently drafting a medical mandated reporting statute for consideration in California and other states. Dr. Jackie Campbell, the leading lethality expert in the country is assisting in this effort. The diverse work group includes advocates, survivors, law enforcement officers, medical professionals, and prosecutors.

The proposal will be reviewed by the Institute’s three standing committees, Medical, Advocacy, and Legal, before it is circulated for additional input from other organizations and then introduced in California. It is time to seek compromise and consensus on the mandated reporting of domestic violence crimes and to ensure that survivors receive the best medical care, documentation, and advocacy support possible. Survivors deserve no less. But we should not ignore accountability for offenders. Isabel Rosales is alive today because of California’s Suspicious Injury Reporting Law. The report by doctors and nurses engaged a criminal justice response from San Diego law enforcement officers and then put Isabel into contact with advocacy and support services the San Diego Family Justice Center and their partner agencies. They wrapped Isabel and her children in safety and support. Her husband went to prison and Isabel started Isa’s Sweets, her own business. She now volunteers as a Hope Coach/Peer Support Advocate for other survivors at the One Safe Place North San Diego County Family Justice Center.

Isabel says it best, “Thank you for not putting all the responsibility for his accountability on me. Thank you for creating a team and letting me be on it with you. Your actions helped me find my worth. You saved my life and helped me realize I really do deserve a beautiful life.”

If you are an advocate, healthcare professional, police officer or anyone else who may come in contact with a survivor of strangulation, make sure to check out the Advocacy Toolkit for Survivors of Strangulation/Suffocation from the Family Justice Center.

Footnotes:

1. Calif. Penal Code §§ 11160-11163.6 (2023). For Isabel’s story, see What Should HealthCare Workers Be Required to Do? CBS 8, San Diego. Available at https://www.youtube.com/watch?v=yQ269frL7W4
2. Ky. Rev. Stat. § 209A.100.
   
3. Colo. Rev. Stat. § 12-240-139 (2023).
4. Tenn. Code § 38-1-101 (2023).
5. Ohio Rev. Code, Title 29, § 2921.22 (2023).
6. Cal. Penal Code § 11160-11163.6 (2023)
7. Calif. Assembly Bill 2790 (Wicks) Proposed 2021-2022 Legislative Session. Retrieved on  Sept. 1, 2023 from https://legiscan.com/CA/bill/AB2790/2021.
8. Senate Appropriations Committee Fiscal Analysis Report, August 28, 2023. Retrieved on Sept. 1, 2023 from https://leginfo.legislature.ca.gov/faces/billAnalysisClient.xhtml?bill_id=202320240AB1028.
9. Calif. Assembly Bill 1028 (McKinnor) Proposed 2022-2023 Legislative Session. Retrieved on Sept. 1, 2023 from https://legiscan.com/CA/text/AB1028/id/2831743#:~:text=This%20bill%20would%2C%20on%20and,practitioner%20suspects%20a%20patient%20has.
10. J.W. August (July 12, 2023). Bill Aims to Nix California Requirement That Hospitals Report Abuse Suspicions to Police [herein-after “Nix”]. KPBS. Available at https://www.kpbs.org/news/public-safety/2023/07/12/bill-aimscalifornia-requirement-hospitals-report-abuse-suspicions-police.
11. Domestic Violence Hotline Blog (Retrieved on Sept. 1, 2023). Survivors of Domestic Violence Report Feeling Less Safe After Contacting Law Enforcement. Available at https://www.thehotline.org/news/survivors-of-domestic-violence-report-feeling-less-safe-after-contacting-law-enforcement/.
12. Nix, supra note 10. 
13. See the unpublished, but widely distributed, DomesticShelters.org survey. Retrieved on Sept. 1, 2023 from https://docs.google.com/forms/d/e/1FAIpQLSfikhWr0AWsYdQjKRrEEBqqxgi4uTprOCJkExoxdgmG4wXv2w/viewanalytics. A PDF version is available by request at: . Publication of the results is pending. The survey respondents were either California advocates, domestic violence survivors or both.
14. Lizdas, K., O’Flaherty, A., Durborow, N. & Marjavi, A. (2019). Compendium of State and U.S. Territory statutes and policies on domestic violence and health care (4th Ed.). In Futures without violence. Retrieved on Sept. 1, 2023 from https://ipvhealth.org/wp-content/uploads/2019/09/Compendium-4th-Edition-2019-Final-small-file.pdf; J. Geiderman & Marco, C. (Feb. 2020). Mandatory and permissive reporting laws: obligations, challenges, moral dilemmas, and opportunities, J. of A. College of Emergency Physicians, 1(1). Retrieved on Sept. 1, 2023 from https://onlinelibrary.wiley.com/doi/full/10.1002/emp2.12011; National Association of Mandated Reporters (NAMR) Blog (2021). Seven professions with a duty to report all types of abuse. Retrieved on Sept. 1, 2023 from https://namr.org/news/7-professions-with-a-duty-to-report-all-types-of-abuse; Mandated Reporting Training Blog (Oct. 13, 2022). Which States Have Mandatory Domestic Violence Reporting? Retrieved on Sept. 1, 2023 from https://mandatedreportertraini....
15. See Training Institute on Strangulation Prevention, Legislation Map (2023). Retrieved August 25, 2023 from https://www.strangulationtraininginstitute.com/resources/legislation-map.
16. Daniel, Nicole S. (Feb. 22, 2023). How preventing domestic violence can reduce historic homicide toll in Birmingham, The Birmingham Times. Retrieved Sept. 2, 2023 from https://www.al.com/news/birmingham/2023/02/how-preventing-domestic-violence-can-reduce-historic-homicide-toll-in-birmingham.html.
17. (n.a.)(Sept. 2022). When men murder women: An analysis of 2020 homicide data. Violence Policy Institute Report. Retrieved Sept. 1, 2023 from https://vpc.org/when-men-murder-women/.
18. Puerto Rico declares a state of emergency over femicides. Retrieved Sept. 1, 2023 from https://www.dw.com/en/puerto-rico-declares-state-of-emergency-over-femicides/a-56332824.
19. When Men Murder Women, supra note 17.
20. Del. Code, Title 24, Professions and Occupation, Chapter 17, Medical Practice Act, § 1762. Retrieved Sept. 1, 2023 from https://delcode.delaware.gov/title24/c017/sc05/index.html.
21. Nix, supra note 10.
22. Glass, N., Laughon, K., Campbell, J.,Block, C., Hanson, G., Sharps, P. & Taliaferro, E. (2008). Non-fatal strangulation as an important risk factor for homicide of women, J. of Emergency Med., 35(3), 329-335. Retrieved Sept. 1, 2023 from https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2573025/.
23. Issues: Domestic Violence, Everytown for Gun Safety (n.d.). Retrieved on Sept. 1, 2023 from https://www.everytown.org/issues/domestic-violence/. See also Gwinn, C., Men Who Strangle Women Also Kill Cops, 19(6) Domestic Violence Report 81 (Aug/Sept 2014); Gwinn & C. Hellman, C. (2018). Hope rising: How the science of hope can change your life (Morgan James Publishing, New York, New York); Alliance for Hope Family Justice Center International Conference, Gwinn, C. (March 2019). Strangulation Presentation. Retrieved on Sept. 1, 2023 from https://www.amazon.com/Hope-Rising-Science-HOPE-Change/dp/168350965X.
24. Gwinn, C., Strack, G., Kingsbury, C. (November 2022). A Dangerous Link From Stranglers to Cop Killers, IACP Police Chief Magazine 54. Retrieved Sept. 1, 2023 from https://www.policechiefmagazine.org/wp-content/uploads/IAC-445-November-2022_WEB_revised2.pdf.
25. See supra note 2.
26. Donaldson, A., Hurren, E., Harvey, C., Baldwin, A. & Solomon, B. (2023). Front-line health professionals’ recognition and responses to non-fatal strangulation events: An integrative review, J. of Advanced Nursing, 79(4), 1290–1320. Retrieved on Sept. 1, 2023 from https://onlinelibrary.wiley.com/doi/full/10.1111/jan.15601
27. Iowa State Univ. Blog (Sept. 27, 2010) ISU team calculates societal costs of five major crimes; finds murder at $17.25 million. Retrieved on Sept. 1, 2023 from https://archive.
    news.iastate.edu/news/2010/sep/costofcrime.
28. Messing J, Campbell J, Brown S, Patchell B, Androff D, Sullivan Wilson J, The association between protective actions and homicide risk: findings from the Oklahoma lethality assessment study, Violence and Victims, 29(4):543-63  (2014), https://pubmed.ncbi.nlm.nih.gov/25199385/. Retrieved on September 2, 2023.
29. Sachs C, Koziol-McLain J, Glass N, Webster D, Campbell J, A population-based survey assessing support for mandatory domestic violence reporting by health care professionals, Women and Health, 35:2-3, 121-133, (Oct. 21, 2008), https://www.tandfonline.com/doi/abs/10.1300/J013v35n02_08.  Retrieved September 1, 2023.