Clemency for Battered Women

Introduction

Leaving an abusive relationship is difficult for many women. On average, battered women attempt to leave abusive partners approximately five to seven times before they are successfully out of the relationship (Ferraro 1998). There are some women, however, who even after numerous attempts to leave have been unable to get away from their violent partners. Leonard (2002), in interviews with incarcerated battered women who had killed their partners, found that they had tried almost every avenue to seek help. This included turning to friends, family, mental health personnel, law enforcement agencies, medical professionals, members of religious organizations, and battered women’s shelters and hotlines. Many of these same women also tried to file for legal separation or divorce. Their attempts to leave or seek help often resulted in the abusive partner becoming more violent. Walker (1989) reported that the batterer often has the mindset that he would rather kill than be left by his partner. Furthermore, many of the agencies (i.e., police, courts, hospitals, and churches) that these women turned to were not able to help due to a lack of understanding about the nature of domestic violence.

When such agencies fail to help, many women feel that they are left deciding between their own lives and the lives of their violent partners (Walker 1989). Death of one of the partners in battering relationships is not uncommon. Statistically, women are more likely than men to be victims of lethal violence by their intimate partners (Browne 1987; Walker 1984). For example, the U.S. Department of Justice (2000) reported that in 1998, 72 percent of homicide victims in intimate relationships were women. When looking at this rate between 1976 and 1997, the female intimate homicide rate remained stable. However, between 1997 and 1998, females killed by their male intimate partners rose by 8 percent. On the other hand, the male intimate homicide rate (males killed by their female intimate partners) decreased by 60 percent between 1976 and 1998. Some professionals attribute this decrease to the increased availability of battered women shelters and crisis centers (Ammons 2003; Browne 1987). These statistics reveal that women are much more likely to be victims of domestic homicide, and their chances of being a victim of lethal violence have not declined over the last few years.

Studies have found that men are more likely to kill when their partners try to leave the relationship (Block and Christakos 1995; Walker 1989), while battered women are more likely to kill in self-defense (Block and Christakos 1995; Gagne` 1998; Leonard 2002; Walker 1989). Walker (1989) reported that very few of the battered women she interviewed who committed homicide killed out of jealousy or revenge. Most battered women who killed reported that they had done so out of fear for their lives. According to their accounts, they had endured emotional, verbal, physical, and sexual abuse before they had killed their partners. They explained that if they had not killed their partners, their partners would have killed them (Beattie and Shaughnessy 2000; Gagne` 1998; Walker 1989).

Gender Bias in the Legal System

Even though it appears that most battered women who kill do so in self-defense, the legal system is often extremely hard on them. Usually women who kill their intimate partners have no prior criminal record (Browne 1987; Walker 1989), yet, these women often receive long and severe sentences (Browne 1987). The claim that battered women are getting away with murder is unfounded (Osthoff 2001). Even with the legal recognition of battered woman syndrome (BWS) in the courts, a large majority (70–80 percent) of abused women charged with killing their partners accepted plea bargains or were convicted and given long sentences in prison rather than having their cases go to trial or being acquitted (U.S. Bureau of Justice Statistics 1995).

Introduced into the criminal justice system in the 1980s, BWS has been used in some states to help explain (through expert testimony) the battered woman’s state of mind at the time of a violent incident. BWS is used as a way to explain the reasonableness that the battered woman feared for her life. While BWS is not a defense in itself, it is used to support a legal claim of self-defense (Dutton 1996). In order to do this, an expert on domestic violence is called to testify in court about the effects of battering (Osthoff 2001).

As of 1994, every state in the United States allowed some degree of expert testimony on BWS into the courts (Parrish 1994). However, prior to the acceptance of expert testimony in court, many battered women were not allowed at their trials to reveal the horrific abuse they had endured in their relationships. They were told they could talk about only the events at the time of the killing and therefore were unable to provide a description of the context in which the killing occurred.

Gender Bias in Self-Defense Law

Many feminist legal scholars and battered women advocates have stated that there is an apparent gender bias within the legal system (Gillespie 1989; Schneider 2000). One example of this gender bias is in self-defense law. Historically, women have been viewed as men’s property and therefore had no independent legal standing (Pleck 1987). Women are socialized to seek help and protection from men. In this context, women should have no reason to learn how to defend themselves. The primary purpose of self-defense law was the right of individuals to protect themselves or their property from an intruder. Self-defense law was not designed with women’s experiences or violence in intimate relationships in mind (Gillespie 1989).

There are two main assumptions in self-defense law. The first is that the person who acted in self-defense did so as a reasonable person. In other words, anyone else in that situation would have acted in the same way. This standard of reasonableness used in some states is based on male status and does not take into account women’s experiences. This is considered an objective reasonable person standard (Ogle and Jacobs 2002). If the defendant’s behavior is inconsistent with that of a reasonable person (white, middle-class, heterosexual male), she did not act in self-defense.

Scheppele (2004) disagrees with the use of one standard and instead argues that there need to be multiple standards of reasonableness. For instance, a white, lower-income woman with two children in a battering relationship is going to see her options or choices differently from those of a white, middleclass man. The choice to leave or stay in a violent relationship is affected by her lack of income, her lack of social status as a woman (i.e., wage gap, lack of affordable child care), her gender socialization (i.e., caretaker, passive, responsible for success of relationships), and her smaller physical stature as a woman. If she is a woman of color, this brings in other issues, such as dealing with racial prejudice and discrimination. Therefore, some states (Ohio, North Dakota, and Washington) use a subjective reasonable person standard (Ogle and Jacobs 2002). The subjective standard assesses whether the person truly felt she was in imminent danger. The jury must ask themselves if the defendant is really telling the truth when she says she feared for her life (Ogle and Jacobs 2002). Just as with the objective reasonable person standard, there has also been dissent about the subjective reasonable person standard. The legal system worries that with the subjective standard, anybody could argue self-defense and state that he or she was in imminent danger. Therefore, there has been a move toward trying to combine the two standards. When states do so, they will assess imminent danger based on a reasonable person similar to the defendant, with comparable resources and knowledge. Thus, a battered woman could be compared with other battered women (Ogle and Jacobs 2002). No states have actually adopted the blending of the two standards, though cases in Ohio, Oklahoma, and South Dakota have applied the idea of combining the objective and subjective standards (Ogle and Jacobs 2002).

The second assumption of self-defense law is that the person acted as he or she did because of a belief of being in imminent danger. ‘‘Imminent danger’’ means that in that moment in time, the person feared for his/her life. This assumes that the defense should occur during an attack, not before or after, and that once the attack is over, the victim is no longer in imminent danger. Imminent danger in abusive relationships is experienced as a constant for many battered women who are in fear for their lives over time, not just during a violent episode (Gillespie 1989).

One other area of self-defense law that is biased against women is the assumption that the two people fighting are of equal size, height, weight, and physical build. Furthermore, self-defense law states that excessive force should not be used to defend oneself. Only if the attacker is armed can an individual use a weapon to defend him/herself (Gillespie 1989). When applying this to a violent intimate relationship, it does not take into account that a person’s body can be used as a weapon. Walker (1989) found that weapons had not injured most of the abused women she interviewed, but instead the injuries had resulted from their partner’s own fists. Many of these women reported being thrown across the room, hit, punched, kicked, stomped on, and choked. For these women, using a gun or a knife was the only way they could successfully defend themselves (Ogle and Jacobs 2002).

However, in most contemporary societies, women are not taught to use firearms (Gillespie 1989). Many battered women who use a weapon to defend themselves do not fully comprehend the lethality of it. There have also been instances in which battered women shot or stabbed their partners not once, but numerous times, claiming that they truly believed that their partner was invincible and that he could never be killed (Walker 1989). According to self-defense law, these women used ‘‘excessive force,’’ which is defined as more force than is necessary to defend oneself (Gillespie 1989).

If juries are told to assess whether or not a battered woman killed in self-defense based only on the legal criteria, the abused woman could easily be convicted of homicide rather than justifiable homicide (Gillespie 1989). A defendant must prove she acted in perfect self-defense to get a not-guilty verdict. Perfect self-defense requires that the defendant truly believes she was acting in part to save her life and that her belief of imminent danger was realistic based on an objective standard (Ogle and Jacobs 2002). As stated earlier, this objective standard may vary from state to state. If, however, she shows that she truly believed she was in danger but her state of mind was not reasonable, she could be found guilty of imperfect self-defense and charged with varying degrees of homicide (Ogle and Jacobs 2002). One response to this bias in self-defense law has been the use of BWS to aid in the defense of battered women who use violence against their partners.

One of the early questions the battered women’s movement dealt with was how to help battered women who had killed or attempted to kill their partners. Activists lobbied for the inclusion of BWS testimony in court hearings in cases in which battered women had killed their abusive partners. Because it took so long for the battered women’s movement to effect changes in the legal system, activists had to change their focus on how to help battered women who were incarcerated. Activists argued that abused women who had killed their partners were imprisoned unlawfully and that it was important for the state to reconsider these cases and grant these women clemency. Clemency has been defined as a ‘‘generic legal term that includes any executive act that reduces or alleviates a penalty for a crime’’ (Gagne` 1998, p. 29). Many battered women’s advocates view clemency as a way to provide justice for abused women who had been unable to defend themselves using the BWS in court.

The decision to grant a battered woman clemency is not always easy. The United States has afforded governors and presidents both political and legal power in this regard. The purpose of clemency is to ensure that our legal system is working effectively and justly. It may be considered one of the checks and balances of our judicial system. However, because governors and presidents are also political actors, they are influenced greatly by public opinion (Ammons 2003). The public’s voice is usually the loudest when it comes to granting clemency to cases involving a homicide. It could be political suicide for governors or presidents to appear soft on crime. Therefore, the governor or president must justify his/her decision to the public and reassure society that a dangerous criminal is not being released (Ammons 2003).

Ohio was the first state to allow a mass clemency review of imprisoned women for crimes related to their history as victims of battering. Dagmar Celeste (wife to then Ohio governor Richard Celeste) was instrumental in this first attempt at a mass clemency for battered women (Gagne` 1998). In 1990, Governor Celeste granted clemency to 25 battered women in Ohio. By the end of his term, he had granted clemency to a total of 28 incarcerated battered women (27 were commuted; 1 on parole was pardoned) (Ammons, 2003). There were two other states that followed suit with mass clemencies for battered women convicted of crimes. Governor William Donald Schaefer granted clemency to 8 battered women in Maryland in 1991, and Kentucky governor Brereton Jones granted clemency to 9 battered women in 1996 (National Clearinghouse for the Defense of Battered Women 2003). Overall there have been a total of 125 battered women granted clemency from twenty-three states (42 of these from Ohio, Maryland, and Kentucky).

Ammons (2003) followed up with the governors of the states that granted clemency to these battered women, finding that they had a variety of reasons for why they granted these women clemency (e.g., illness, punishment too severe, BWS, sufficient time served, ineffective counsel). The most cited reason was that the governors felt that these women were ‘‘trapped in relationships because of a mental deficiency, a ‘syndrome’’’ (p. 557). The second most cited reason was that these women had been unable to tell about the battering in their relationships at the time of the trial. Rather than the governors justifying these women’s actions, they excused them based on the abuse they had endured and society’s failure to help them.

It is important to keep in mind that all of these women (with the exception of the one woman in Ohio) had their sentences commuted. A commutation replaces the original punishment/sentence with a less severe one (Sheehy, Reinberg, and Kirchwey 1991). Thus, many of these women still had to serve some type of sentence and/or go before the parole board. Appearing before the parole board was not always a guarantee that parole would be granted. A commutation also does not exonerate the person of the crimes he/she has committed. These battered women still had to deal with having a felony conviction that stripped away many of their civil liberties and made it difficult for them to find employment and housing.

Clemency and Recidivism

Even though these women have difficulties finding employment with a felony conviction, the majority have been able to live violence-free lives. There was great public upheaval over granting convicted battered women clemency because many in society worried that these women would kill again. Ammons (2003) researched the recidivism rate for the twenty-eight women in Ohio who were granted clemency in 1990. The overall recidivism rate for female violent offenders was 23 percent. The clemency recipients’ recidivism rate for a felony murder was 0 percent. Ammons found that one woman had a drug-related charge against her and another woman a property offense. Two women have since passed away (Schneider 2006). The rest of these women are leading crime-free lives.

Issues Confronting Women Who Do Get Clemency

Gagne` (1998) conducted a qualitative study with women who had been incarcerated in the Ohio prison system for killing their abusive partners and received clemency. Gagne` interviewed eleven of the twenty-five women who were granted clemency in Ohio in 1990 soon after they were released from prison. The interviews revealed that women who received clemency felt that killing their abusive partner had been their only option. They said they had felt trapped and that they had had no other viable options to stop the abuse. They also felt that if they had not killed their abusive partners, they would have been killed instead. Furthermore, these women discussed at length how they felt they had been victimized repeatedly by unsympathetic social service agencies as well as the judicial system.

Another study on battered women’s lives after clemency was conducted by Beattie and Shaughnessy (2000). They conducted oral history interviews in 1995 with nine battered women who became eligible for parole at the Kentucky Correctional Institution and were granted clemency. All of the women talked about lives filled with childhood abuse (most often sexual) and how this abuse continued into adulthood when they entered into intimate relationships. These women described relationships filled with horrific abuse and communities where no one seemed to care. They spoke of contacting authorities and being victimized repeatedly by people who refused to do anything. For example, one woman told the story of her community being so afraid of her partner that when she would call the police, the police would stand at the bottom of her driveway and yell at her husband. The police in this instance were so terrified of this man that they would not come face to face with him. As a result they let him abuse his wife for years and did nothing to stop him.

The interviews in both studies revealed that these battered women felt they had killed in self-defense to end the abuse. They tried to seek help before they acted and were unsuccessful. They feared for their lives and felt they had no options. These women also spoke of great inequities within the criminal justice/legal system during their questioning, arrest, sentencing, and trial. Many were unfamiliar with the court system and were terrified of losing their children (which was often used as a threat). They spoke of inadequate representation and attorneys who were not sensitive to battered women. Some of the women talked about being scared to talk about the battering because their attorney was a male. Others talked about their attorney dismissing the battering and not wanting to bring it up because he/she was not familiar with laws pertaining to battered women (Beattie and Shaughnessy 2000; Gagne` 1998).

Once these women were given the opportunity to apply for clemency and were granted it, they spoke of their lives after prison. Because in both Ohio and Kentucky these women were not pardoned (removal of felony conviction and exoneration), but instead had their sentences commuted (replacement of less severe punishment), they still had a felony conviction on their record (Sheehy, Reinberg, and Kirchwey 1991). This had a huge impact on their life after clemency, as it was difficult for them to find employment, housing, and assistance. These women struggled with reestablishing their relationships with their children, and many suffered from depression and anxiety. The majority commented that without the help of their family, they could not have made it on their own (Beattie and Shaughnessy 2000; Gagne 1998).

One of the most difficult things women granted clemency had to deal with was having a prison record. Due to the fact that in both states the women had their sentences commuted and were not pardoned, their felony convictions stayed with them. This influenced everything in their lives outside of prison, from gaining employment to obtaining adequate housing to how individuals (family, friends, and community workers) related to them. In Gagne’s (1998) sample, none of the women were able to go back to the places where they had been employed prior to their incarceration due to their felony convictions. In both studies the women talked about how finding employment was one of the most difficult challenges and that they relied heavily on family for financial support after release from prison.

Related to finding employment is finding adequate housing. One of the conditions of leaving prison is often to report the address where you will live outside of prison. For many women, this is the only prerelease planning they are given (O’Brien 2001). Most of the women in both studies reported living with family after release. However, there were a couple of women who had no family and had to rely on halfway homes. These women had been in prison most of their lives for killing their abusive stepfathers and had a really hard time adjusting to life outside of prison, since that was the life they knew best (Gagne 1998).

Another major hurdle the clemency recipients had to deal with was reuniting with their children. In some cases, due to parole conditions, the women were not allowed to see their children. In other situations the children were still very angry and blamed their mothers for their own victimization by their fathers, stepfathers, or mothers’ boyfriends. Some women dealt with older children who had become caught up in their own abusive relationships, and these women had to figure out how to help in a way that was not too aggressive. The women tried very hard to reconnect with their children, but it was not something that came easy. This experience is common for mothers who have served time in prison (Hunter 2005).

Some women also had to contend with the family of the abusive partners they had used violence against. One woman in Beattie and Shaughnessy’s (2000) study reported that due to parole conditions, she could not contact her abuser’s family; however, they continued to contact her through harassing phone calls. Another clemency recipient from Ohio talked about the fear of seeing her abusive partner, who had survived the attack. Because of victim’s rights, he was contacted when she was let out of prison, yet she had no protection from him (Gagne 1998).

These women also had to deal with the decision of whether to get involved in another intimate relationship. The majority talked at great length about their fear of commitment and mistrust of everyone. One woman spoke of still wearing her wedding ring because she still felt controlled by her husband even though he was dead (Beattie and Shaughnessy 2001). Some women from both studies ended up in abusive relationships again. Some of these women were able to get out of these relationships, while others were still trying to figure out how to disentangle themselves from the vicious cycle of abuse. Gagne (1998) reported that the women who had had abusive childhoods (especially sexual abuse) had an extremely hard time moving into a life free of abuse. Many of the women chose not to have any intimate relationships because of a lack of trust.

Granting clemency to incarcerated battered women is only a small step in providing justice for battered women who defend themselves. Because of their felony convictions, it is not easy for these women to enter back into society. They are continually victimized over and over again as they are denied employment, housing, and custody of their children, repeatedly reinforcing the fact that they are on their own. Prior to incarceration, many of these women dealt with poverty, racism, and sexism. Post-prison they face the same barriers, and now they have a felony conviction to contend with as well (Richie 2001). Gagne` (1998) found that support groups in prison aided in the reintegration of women back into society post-prison. However, Richie (2001) reported that the counseling, support groups, mental and physical health care, and educational/ employment services that prisons offer are minimal. Many of the women in Richie’s study (incarcerated for a variety of offenses, not just killing/attempting to kill battering partners) stated that they were not prepared at all for life after prison. They suffered from PTSD and multiple mental and physical health issues, and those with addiction problems had difficulty maintaining sobriety.

Issues Confronting Women Denied Clemency

Women who are denied clemency are confronted with the reality that the governor and/or parole board do not justify or excuse their actions to use violence against their battering partner. Schneider (2006) interviewed eleven incarcerated battered women in Ohio who were denied clemency. These women, just as the women who received clemency, reported lives filled with abuse. They were also confronted with societal indifference and felt that the abuse they endured was condoned. They reported that they felt their lives or their children’s lives were in danger and that they had had no other choice but to kill in self-defense. Unfortunately, many of these women spoke of inadequate attorneys and witnesses who testified against them in their trials. Furthermore, these battered women were not like the ‘‘stereotypical battered woman.’’ They had character flaws (i.e., they drank alcohol or used drugs, they’d had extramarital affairs, and they denied the abuse their children endured from their partner), which hurt them in their trials as well as in the clemency proceedings.

These women continue to live their lives incarcerated within a system which they reported is not rehabilitative. They stated that rehabilitation came from inside each person. They reported that some prison support groups were available, but because most of the women have life sentences, they have completed the majority of the programming and there is very little left for them to take while in prison. Many of them have tried to further their education by completing their general equivalency degree (GED) and taking college courses. Unfortunately, due to budget cuts and overcrowding at the prison, much of the college programming has been cut. For example, prisoners are no longer able to earn a college degree in the Ohio prisons, only certificates. They have taken it upon themselves to start battered women support groups and have started to look at themselves as survivors rather than victims. However, this change in identity is a double-edged sword. When these women go before the parole board, the board does not want to hear that they have survived years of abuse and were justified in defending themselves. Therefore, most of the women have life sentences and remain in prison, where the parole board continually denies them an exit to the outside world.

Furthermore, these women struggled with not being able to see their children. Most of the children ended up living with family. Unfortunately, some living situations for these children have been as abusive as their home life prior to their mother going to prison. Some of the children were bounced around from one foster home to the next. Some of the women have been able to keep in touch with their children, while others have struggled with the reality that they may never see their children again. These women have missed out on their children’s entire childhoods, as many were sent to prison when their children were just in elementary school. Reestablishing a relationship with their children will most likely be very difficult, if and when they are released from prison.

If these women do get out of prison, they will face many of the same challenges that the women who received clemency faced. However, these women will be unable to say to their communities that they were legally justified or excused for killing (or attempting to kill) their violent partners or family members. These women will most likely have difficulty finding employment, will have little social support, and will be faced with communities that view them as killers.

Conclusion

Clemency is a way to ensure our legal system is really just and fair. It is a way to provide ‘‘justice . . . when you get what you deserve, mercy . . . when you don’t get what you deserve, or grace . . . when you get what you don’t deserve’’ (Ammons 2003, p. 551). Clemency gave a voice to battered women and allowed society to hear about the abuse these women endured. Unfortunately, society has heard very little about the hardships these women encountered after clemency or the structural factors that affected battered women who were denied clemency. Many feminist scholars feel that clemency is just one small step toward equality for women and that there is much more that needs to be done (Beattie and Shaughnessy 2000; Gagne` 1998; Schneider 2006).

One clemency recipient in Gagne’s (1998) study stated that she wanted her life back along with her freedom and that she feels she has neither since she has been out of prison. She has struggled with alcohol addiction, lack of employment, physical and mental health problems from the abuse in her past, and frustration with her inability to obtain adequate housing because of her felony record. Society obviously needs to do much more to support battered women. It is not enough to just give them a ‘‘get out of jail free card’’; society must also provide the services they so greatly need and are unable to obtain.

There needs to be more research on life after clemency, and these women’s stories must be told to the public. This information could help alleviate sources of strain and aid in helping incarcerated women adjust to life outside once they are released from prison. Furthermore, these women’s stories also need to be shared so that the public understands what clemency means and that there is empirical support that shows that these women are not career criminals. Ammons (2003) found that the assumption that battered women are dangerous criminals is unfounded and that these women’s violent actions were isolated incidents. Policymakers must hear these women’s stories so as to understand the changes needed in our criminal justice system, hospitals, churches, and neighborhoods.

Read more about Domestic Violence Law. Also check the list of domestic violence research topics or all criminal justice research topics.

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