From East of
Eden to the Pyramids:
White-Collar
Crime in the North Carolina Context:
The 2016 Presidential Address
by
Steven E. Gunkel
Wake Forest University
Introduction
How many of us begin our day with a
doughnut or oatmeal, quickly brush our
teeth, log-on to the internet, or maybe
run a logistic regression using
SPSS? Many folks often engage in
several of these routine activities yet
fail to consider the way these habits
unwittingly connect us to a long list of
firms that are guilty of white-collar
crime. Our doughnut, if courtesy of
the Winston-Salem based Krispy Kreme, is
sold by a company found guilty of
fraudulently stating profits in SEC
filings. Nearly a decade ago, the company
inflated its quarterly and annual
earnings, thus misrepresenting a prime
benchmark of its historical performance
(SEC 2009). Our oatmeal, if Quaker
Oats, was produced by a company that
teamed-up with the Massachusetts Institute
of Technology in the 1940s and 1950s and
used cognitively challenged and
unsuspecting subjects to test the effects
of radioactive oats. The case was settled
for $1.85 million, with the majority paid
by MIT (Hussain 1998). Celanese
Corporation, which manufactures the
polymers found in many of our
toothbrushes, is responsible for one of
the most contaminated Superfund sites in
the nation. This site, located in Shelby,
North Carolina, was placed on the U.S. EPA
Superfund National Priorities List in 1986
and Celanese was ordered to undertake a
$3.7 million clean-up of contaminated
groundwater and soil at the site (U.S. EPA
1989). Our internet provider, if
Time Warner Cable, has also been found
guilty of corporate misconduct. TWC
overstated revenue, misrepresented
subscribers and engaged in securities
fraud; the company was ordered to pay a
$300 million fine (U.S. Department of
Justice 2008:1.25-1.26). Lastly, the
software used by many sociologists, the
Statistical Package for Social Sciences
(better known as SPSS), is owned by
IBM, a company that once partnered with
Nazi Germany to provide the tabulation of
Jewish concentration camp prisoners (see
Bakan 2008:88-89; Friedrichs
2010:160).
Lest we regard these five instances as
anomalous or the byproduct of selection
bias, consider another set of corporations
that are woven into the fabric of our
lives: Boeing, Westinghouse, General
Electric, General Motors, Johnson &
Johnson, and British Petroleum. In
brief, Boeing, the aerospace giant, was
linked with contractor and procurement
frauds victimizing the federal government;
Westinghouse and GE participated in a
multi-million dollar price-fixing scheme;
General Motors and Johnson & Johnson
have produced unsafe automobiles and
pharmaceuticals, respectively; and the
BP/Deep Water Horizon oil spill of the
Gulf Coast ranks among the worst
environmental crimes in U.S.
history.
These as well as hundreds of other cases
provide an important reminder that white
collar-crime remains pervasive and costly,
imposing devastating burdens on
individuals and communities. Despite
these costs, neither the general public
nor political leaders adequately
acknowledge the problem that corporate
crime represents. The mismatch
reflected in our limited awareness of
white-collar crime despite its exorbitant
costs motivates this address. The analysis
of corporate crime which I will provide is
guided by a threefold purpose.
First, I will examine two recent cases of
white-collar crime in North Carolina: the
Duke Energy coal ash spill, an
environmental crime that ranks among the
worst such cases, and the ZeekRewards
Ponzi scheme, an economic crime also of
vast proportions. Second, I situate
these cases with respect to consequences,
typologies, and sanctioning of
white-collar crime; and finally, I trace
productive paths for moving forward with
our understanding and control of
white-collar crime.
Framing White-Collar
Crime in North Carolina: Sutherland's
Intellectual Legacy
In order to situate the complexities
underlying white-collar crime in North
Carolina, it is important to first
establish the evolution of the
concept. In the 1940s, Edwin
Sutherland's (1985) pioneering efforts
linked criminal offending with the
legitimate production of goods and
services. With this work,
Sutherland hoped to discount poverty-based
explanations for crime, redirect the
efforts of criminology to focus on
white-collar crime, and establish support
for his theory of differential association
(Sutherland 1940). To this end, he
examined corporate misconduct among a
large sample of 70 leading
corporations. Using this sample, he
empirically established the prevalence and
incidence (recidivism) of white-collar
crime across a period that spanned a
half-century (1890-1944) (Sutherland
1985:13-25). All corporations
studied had at least one adverse decision
for corporate misconduct registered
against them with an average of 14 adverse
decisions for the sample (one corporation
garnering 50 such decisions).
Sutherland's analysis also clarified the
importance of a more expansive definition
of white collar crime to include not only
cases that resulted in criminal sanctions
but also those that resulted in regulatory
(administrative) and civil remedies.
Importantly, only about 16% of the adverse
decisions uncovered in his analysis were
actually rendered by the criminal courts
with the vast majority being
"administratively segregated" into the
civil and regulatory courts (a pattern
which persists to the present day).
His legacy and sociolegal outlook continue
to inform the efforts of criminology and,
in my interpretation of the case studies,
I borrow from both his emphasis on
corporate offending and the sanctioning of
these offenses (i.e., to include not only
the criminal sanction but also regulatory
and civil remedies). (1)
Environmental
White-Collar Crime in North Carolina:
East of Eden
On February 2, 2014, a massive coal ash
spill occurred at a Duke Energy plant
located approximately 10 miles east of
Eden. This spill has become widely
defined as one of the most significant
environmental white-collar crimes
nationally as well as locally, given Duke
Energy's dominant status as a company, the
political and economic dynamics
contributing to this misconduct, and the
scope of the damage done. Duke Energy,
headquartered in Charlotte, is the largest
electric power company in the U.S. as it
employs over 28,000 individuals, and
services an area that covers some 95,000
square miles with 7 million customers in
the Southeast and Midwest. As a
Fortune 250 Company, Duke holds over $120
billion in assets, with total annual
profits of approximately $2.7 billion (see
Henderson 2014; Duke Energy 2014).
The Duke Energy spill dumped 39,000 tons
of coal ash into the Dan River which ranks
as the third largest coal ash spill in
U.S. history. (2) The bottom of the
Dan River was coated with coal ash for 70
miles downstream, posing a carcinogenic
threat to drinking water and aquatic
life. Experts like Lynn Ringenberg
with Physicians for Social Responsibility
emphasize "Coal ash contains the deadliest
heavy metals on the planet earth… it's
mind boggling" (Camp 2014).
Specifically, the metals found in coal ash
-including arsenic, chromium, mercury,
cadmium, and selenium - can cause cancer,
liver damage, neurological disorders and
other health problems. Even so, the
U.S. EPA doesn't classify coal ash as a
hazardous material further complicating
the regulatory oversight of these
production practices (see Gang, 2013).
The spill was not an isolated incident
with at least three other documented
instances which established a pattern of
noncompliance with the Clean Water Act
(CBS News/AP 2015). Duke Energy's
illegal pollution dates back to 2011 and
demonstrated a pattern of
negligence. The NC Department of
Environmental and Natural Resources
(NCDENR) was also widely faulted for not
effectively responding in this
case. In part, the agency was
struggling with budget cuts that left
officials with limited
resources. In addition,
pro-industry bias at the highest levels
within the agency contributed to a failure
to enforce and promulgate regulations that
would minimize the risk of coal ash
spills. Many agency employees became
fearful they would be fired if they
advocated for more stringent environmental
enforcement (Gabriel 2014).
Experts agree that it will take years to
accurately assess the costs of the Duke
Energy coal ash spill. One analysis
pegged the financial cost of the spill at
$295.5 million within the first six
months, as a result of harm done to the
environment, human health, and business
(see Wireback 2015). As in other
cases of environmental white collar crime,
the damages are most immediately borne by
a set of economically vulnerable
communities. In this case, the coal
ash spill threatened the revitalization of
an economy that once depended on textiles
and tobacco. According to Joe
King, City Manager of Danville, Virginia,
which sits 20 miles downstream from the
breached coal ash pond and arguably faces
potentially the greatest cost, the spill
"hurt our momentum" in rebuilding the
economic vitality of this former
manufacturing center. "We're trying
to sell Danville as a great place to live
and do business. We've invested in
the river district" (Adamson 2015).
But a new marketing campaign to draw
people and business to the area was put on
hold as a result of the spill.
Some local businesses that depended
heavily on burgeoning tourism (such as
boating outfitters) cited losses of as
much as 40% in the year following the
spill (Wireback 2015). Local
farmers who depend on the Dan River to
irrigate crops and water livestock faced
uncertainty until NC State University
scientists issued a report declaring the
water safe for these purposes. They
cautioned farmers, however, that
conditions could change as the coal ash
remained on the river bottom. A
recreational water advisory was also in
effect for four months, cautioning against
use of the Dan River for boating, swimming
and other activities that could result in
contact with the coal ash (Dalesio
2014). More than a year after the
spill, an advisory issued by the
Department of Health and Human Services
remained in effect, warning that a
potential fish and shellfish consumption
hazard still exists immediately downstream
of the release. In Danville as
well as other localities fed by the Dan
River, fears about the water supply
persist among many residents who refuse to
drink the water, skeptical of tests that
declare this source to be "problem free"
(Wireback 2015).
On May 14, 2015, Duke pled guilty to nine
(misdemeanor) counts of violations of the
Clean Water Act. As part of their
plea, Duke Energy was ordered to pay $102
million in criminal fines and restitution
to the federal government and the company,
placed on five years federal probation,
was also ordered to pay a $6.6 million
civil fine to North Carolina.
While this environmental white-collar
crime occurred some 45 miles east of
today's conference, another kind of
corporate misconduct, in this case
involving a massive pyramid scheme,
recently played out in a town just 20
miles south of Winston-Salem. Orchestrated
by a former nursing home magician, I turn
now to an overview of the tricks and
subterfuge underlying this case.
Economic White-Collar
Crime in North Carolina: To the
Pyramids
The ZeekRewards case, which originated in
the once thriving textile and furniture
manufacturing town of Lexington, involves
a far-flung, internet-based, pyramid
scheme combined with a classic Ponzi
scheme, promising profits that seemed "too
good to be true" (Weis 2013).
ZeekRewards, via its companion website
Zeekler.com, was promoted as an online
investment "opportunity" which allowed
participants to bid for items (such as
iPhones) in a penny auction format.
ZeekRewards was touted as invitation-only
for its participants who could earn
incentives for promoting ZeekRewards on
other websites and, importantly, by
recruiting additional members (i.e., its
pyramidal, multilevel marketing, and
unstable aspect). The scheme
involved 2.2 million individuals with
customers numbering 220,000 in the U.S.,
including 47,000 North Carolinians (Craver
2016). The scheme raised
approximately $850 million, pledging to
provide investors returns of 125% within
90 days and 500% annually which was tied
to a purportedly freely fluctuating rate
of return but was, in fact, unilaterally
and arbitrarily set by the founder so as
to give the appearance of profitability
and stability for investors (see Craver
2015; SEC v. Burks et al. 2012).
ZeekRewards followed the classic arc of a
Ponzi scheme. The bustling
headquarters at 803 W. Center Street was
teeming with baskets stuffed with
investor's checks while the illusion of
stability (and profitability) was
maintained as investors requesting
payments were paid (unbeknownst to them)
from monies collected from new
investors' funds (Weiss 2013). (3)
ZeekRewards ran for nearly three years,
from January 2010 until regulators shut it
down on August 17, 2012. Interestingly,
complaints regarding the fraudulent nature
of ZeekRewards were filed with the NC
Attorney General's Office and the NC
Secretary of State as early as November
2011. However, regulators failed to heed
these warnings -- which allowed the scam
to run for almost another year (Weiss
2013). It is estimated that
approximately 800,000 investors lost money
in the scheme (Craver 2015).
According to Sarah Chavez, who invested
$7000 in the scam, "It's hard to believe
in something like that. But everyone told
us it was a sure thing," Sadly, Ms. Chavez
had invested in ZeekRewards hoping to
secure additional funds to help cover the
costs of her daughter's hospital
treatments for leukemia (Weiss 2013).
The founder, Paul Burks, was charged with
mail- and wire-fraud (and conspiracy to
commit) and tax fraud. While Burks
has agreed to pay a $4 million dollar
penalty (and cooperate with the receiver
appointed to recover funds in the case),
his criminal trial is pending and the
total counts could lead to a 65-year
prison term and fines in excess of $1
million (see Weiss 2013; Craver 2015).
Other co-conspirators in the scheme
include Dawn Wright-Olivares (who served
as COO), her stepson Daniel Olivares (who
served as Chief Technology Writer and
architect of the computer database used in
the fraud), and her fiancée, Alex de
Brantes (who served as Internet Marketing
Manager). Dawn Wright-Olivares pled
guilty to securities fraud, has disgorged
$8.1 million in unlawful profits and could
receive a ten-year prison sentence; while
Daniel Olivares has also pled guilty to
securities fraud, disgorged $3.2 million
in profits, and could net a five-year
prison term (SEC 2013; Dunn 2014).
Having provided an overview of two of the
historically largest and most recent cases
of environmental and economic white-collar
crime in North Carolina, I turn now to
examine their fit with general themes
underlying our understanding of
white-collar crime.
Broader Themes and
Lessons Illustrated in the North
Carolina Cases: Red Herrings,
Typologies and Sanctioning
The Duke Energy coal ash spill and the
ZeekRewards pyramid scheme clarify several
broader themes and lessons emphasized in
white-collar crime scholarship that should
guide further analysis, debate and
policy. First, these two cases
counter two red herrings commonly
associated with white-collar crime – the
crimes only do financial harm; and the
harm of the offenses is not as great as
common crime ("street crime").
Clearly, in the case of the Duke Energy
coal ash spill, this offending created
massive environmental damage and physical
harm remains a possibility (due to the
carcinogenic substances released).
This comports with the widely accepted
consensus among scholars that white-collar
crime should be properly classified as
violent -- and often much more so than
street crime (see Friedrichs 2010: 68-77;
Reiman and Leighton 2013:65-117). The
second red herring, which treats the costs
of common crime as greater than the costs
of white collar crime, is similarly
countered by these cases. Any single
case of white-collar crime may eclipse the
most expensive case of street crime and
white-collar crime is always more costly
than all street crime combined within any
reporting period (and these are for the
white-collar crimes of which we are
aware). Considering the fiscal and
physical costs, importantly, the Duke
Energy case and the ZeekRewards case rank
among the most costly crimes recorded in
North Carolina as well as
nationally.
The two case studies also illuminate the
value of emerging typologies used to
describe white-collar offending (see
Friedrichs 2010 for an overview of these
"hybrid" typologies). In both cases,
we might make use of a hybrid form of
white-collar crime - "state-corporate
crime" - which links dynamics common to
governmental crime and corporate
crime. This typology suggests
white-collar crime reflects a synergistic
relationship between the government, on
the one hand, and the corporation on the
other in that the crime in question cannot
be accounted for solely by looking to the
corporation or the government (as in the
case of the IBM/Nazi regime cited
earlier). In the coal ash spill, we
can point to the extremely lax and
"defanged" NCDENR furthering and/or
exacerbating the offending and its
consequences (Gabriel 2014).
Interestingly, the defanging of this
regulatory agency (which was once regarded
as among the strongest in the Southeast)
has been attributed to the actions of
Governor Pat McCrory who worked for Duke
Energy for almost three decades before
taking office. Similarly, the
ZeekRewards case points to lax regulation
and the failure to step-in when state
actors had the opportunity to do so
thereby allowing the fraud to run for
almost another a full year and compounding
losses.
A second typology that we might consider
is that of "contrepreneurial crime" which
is also a hybrid that links professional
crime with white-collar crime. Here,
the blurring of the boundaries between
legitimate investment opportunities (and
agents promoting them) can be seen by the
con(fidence) men promoting pyramid and
Ponzi schemes. Thus, in the
ZeekRewards case, we see these elements of
"confidence" men and women, such as Paul
Burks and Dawn Wright-Olivares engaging in
professional crime in which they
effectively pose as agents of a legitimate
business venture (ZeekRewards) affording
investment opportunities.
Interestingly, one of North Carolina's
newest residents, Bernie Madoff, is now
serving a 150-year sentence for the
securities (and other) frauds underlying
his massive $65 billion Ponzi scheme that
serves as yet another exemplar of the
"contrepreneurial crime" typology (see
Friedrichs 2010:204-207; Gunkel 2013). A
third typology, "technocrime" uniquely
describes the ZeekRewards case in that
computer technology itself has expanded
the opportunities for both occupational
and organizational forms of white-collar
offending (Friedrichs 2010:211-217).
Indeed, the investment opportunities were
touted extensively within and proliferated
in cyberspace and investors were recruited
and informed of their earnings in an
internet-based investment vehicle (and,
ironically, the computer-based nature of
the fraud may have enhanced its perceived
legitimacy among its customers).
Showing the elasticity of and room for
growth in our use of these typologies,
ZeekRewards illustrates how perpetrators
can actually pursue the dual aims of Ponzi
and pyramid schemes (and Burks gradually
relied upon his multilevel marketing
experience to prop-up the Ponzi scheme)
while using technology that state actors
may not fully understand or regulate in a
timely fashion.
The two cases also highlight important
sanctioning mechanisms used in
white-collar crime cases.
Interestingly, the two cases were selected
for their North Carolina context and
currency but they represent a rather
exceptional and extraordinary sanctioning
pattern that may serve as a model for
other cases nationally. That is, the
outcomes (to date) represent the "road not
taken" typically; each culminated in the
rarely used criminal sanction (see Shapiro
1985; Schlegel, Eitle and Gunkel
2001). Duke Energy, as a corporate
entity, was ordered to pay substantial
criminal fines for their misconduct, even
though the company was found guilty of
only misdemeanor offenses. Individual
actors within the ZeekRewards case have
been convicted (or will face criminal
trial) for their actions with some actors
required to disgorge profits earned and
face possible incarceration terms for
their role in the fraud. In
important ways, the enormity, visibility,
duration, culpability, and blameworthiness
evident in each case contributed to this
rather punitive response to these
environmental and economic crimes – itself
a recurring theme in the white-collar
crime literature that focuses on the
factors that shape sanctioning.
(4)
Having examined the ways in which the two
cases reflect on misperceptions,
typologies, and sanctioning of
white-collar crime, I will close by
examining the ways we might move forward
in our understanding of and efforts to
control white-collar crime.
Moving Forward
As my opening statements indicated,
numerous goals motivated the focus on
white collar crime in this address.
First and foremost, I hope to push
white-collar crime to center stage in
debates and discussion of crime,
punishment and restitution more generally,
highlighting its pervasiveness and costs,
the conceptual tools sociologists offer to
clarify its dynamics and, in turn, guide
policy to more effectively counter
corporate crime. To begin, we
must spearhead more deliberate efforts to
recognize the scope of the problem in this
state as well as nationally. While
most conference attendees had probably
heard about the coal ash spill (as it
received widespread and national media
coverage), perhaps fewer had heard of the
Ponzi and pyramid scheme launched right
here in North Carolina. This, like
so many other white collar crimes, has too
often been made invisible by official
narratives focusing on street crime.
The failure to see white-collar crime for
the crime it is and the harm it does
represents a problem and an opportunity at
once. Sociologists can and should
play a key role uncovering this crime and
its costs as well as serving as a resource
for individuals and communities victimized
by this corporate misconduct.
Indeed, a recent conversation with a
colleague (with the pseudonym of "Fred")
inspired this address with this in
mind. First, this conversation
provided a powerful reminder that white
collar crime, even when it hits close to
home, is rarely recognized as
such. Fred, my
colleague, hailed from a town in the U.S.
in which a large corporate fraud (totaling
hundreds of millions of dollars) had
recently unfolded, the fraud became the
focus of a Frontline documentary and yet
he had never heard of this scheme!
In so many ways, we have a local, state,
regional, national, and global "blindspot"
when it comes to white-collar crime.
Fred's experience and that of the general
public is significantly shaped by the
"social reality of crime" which is largely
reflected in and reinforced by the media
itself. In current media
representations, street crime,
terrorism, and sex crimes receive about
90% of attention while accounts of
white-collar crime amount to less than
two-percent (2%) of all media coverage
(see overview in Brown, Esbensen and Geis
2015: 12-13). In an applied sense,
sociologists need to make ourselves
available to media outlets or engage in
"newsmaking criminology" (5) so as to
reverse the profound disparities in crime
coverage which treat street crime as
posing the greatest risk and harm
while simultaneously ignoring the far
greater problems posed by white-collar
crime. My hope is that this address
and our work as sociologists might help
redress the ignorance of the vast harm
done by these criminal offenses.
Whether my phone rings or my inbox is
filled with media inquiries, we as
sociologists can play a critical role
shifting news coverage from its current
fixation on street crime to recognize the
greater impact of white-collar crime.
We can also play a critical role as victim
advocates, and in so doing perhaps engage
in the kind of "activist criminology"
Joanne Belknap (2015) has recently
encouraged. I was presented with
precisely this opportunity in another
conversation with my colleague Fred, whose
friend was victimized not too long ago by
a Ponzi scheme that cost him over
$60,000. As I listened to
Fred's account, I quickly understood the
nature of his friend's victimization and
provided some detailed guidance regarding
possible strategies to recoup losses and
alert the authorities. My years of
training and research have convinced me
that too many victims of white-collar
crime face a common set of challenges in
securing justice: they are often unaware
of the harms suffered; they are often
ignored by the system; they typically do
not know where to turn for help; and they
generally lack support in their efforts to
seek redress for the harms they
suffer. Fred's friend
was engaging in self-blame for his
victimization (a common response for those
falling prey to fraudsters), was not sure
who he should turn to in order to report
the victimization, what source(s) he
should consider to determine if others
have been victimized by the same
perpetrator, was not sure if he had a
legal case, and was unable to locate legal
counsel. In fairly short order, I
was able to convey to the friend (via
Fred) that: the victim should resist the
temptation to blame himself over the large
sum of money that was taken; reporting to
local, county, and state police (and State
Attorney General) was critical; consulting
the Securities and Exchange Commission,
Consumer Financial Protection Bureau,
State Attorney General and Secretary of
State could prove useful; and contacting a
legal aid clinic and retaining counsel was
essential. Sadly, while
well-intentioned, Fred was attempting to
gather much of the information in a
painstaking and cumbersome manner and was
very grateful for the advice given (and
sources to be pursued) and the victim was
able to retain legal counsel. The
case is pending but it appears that the
criminal activity was not an isolated
incident and perhaps a portion of the
financial losses can be recouped in the
future.
Whether Fred's friend and other victims of
white-collar crime receive justice remains
to be seen. However, if we can advance a
critical re-examination of routine
activities associated with our typical
(hypothetical) day and their intersection
with white-collar crime; (6) glean
an even deeper appreciation of what these
two cases of white-collar crime in North
Carolina represent and where they can take
us; and step-up to the challenges
associated with "newsmaking criminology"
and "activist criminology", perhaps the
prognosis is brighter for meaningful
control of these offenses.
Footnotes
(1) The seminal
efforts of Clinard and Yeager
(1980) use a "modified legalistic"
framework advanced by Sutherland
in which they identify illegality
using criminal, civil, and
regulatory sanctioning of the 477
largest corporations studied. I
have often relied on this style of
inquiry in my own empirical
efforts examining white-collar
crime (see Wahl, Gunkel and
Sanchez 2000; Wahl and Gunkel
1999; Gunkel 1996).
(2) The largest spill occurred in
Kingston, Tennessee on December
22, 2008 -- dumping 5.4 million
cubic yards of coal ash which was
more than the amount of oil
released in the BP/Deepwater
Horizon spill cited earlier (see
Gang, 2013).
(3) For a fascinating account of
the ways in which Charles Ponzi
cultivated the aura of
profitability and stability among
his victims, see Zuckoff (2006).
(4) Interestingly, at my
presidential address, some
attendees questioned whether the
environmental offenses were
actually crimes despite the
successful application of the
criminal sanction. Most
criminologists side with
Sutherland’s position that the
"administrative segregation" of
white-collar offenses creates a
low probability of criminal
conviction and the need to take
into account civil and regulatory
sanctioning for a meaningful
representation of the realities of
white-collar offending (see
Sutherland 1940). The
exchange sparked by this address
speaks to the tensions identified
by Sutherland. And yet, we often
fail to see white-collar crime as
a crime based on the type of
sanction it typically receives,
even when it does merit and has
actually received criminal
sanctioning.
(5) For cautionary tales regarding
his experiences with newsmaking
criminology (since coining the
term in 1988) and specific
strategies for promoting a media
presence, see Barak (2007).
(6) The use of the term "routine
activities" is purposive as this
theoretical model holds
considerable promise for
explaining the causes of
white-collar crime in that the
"crime triangle" linking motivated
offenders, suitable victims, and
an absence of effective
guardianship fits remarkably well
with the dynamics cited throughout
my presentation (see Friedrichs
2010:234).
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Belknap, Joanne. 2015.
"The 2014 American Society
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Activist Criminology:
Criminologist's
Responsibility to Advocate
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