Mike Nifong has become a convenient scapegoat for avoiding the real lessons of the Duke debacle: abuse of procedure and the cost of justice in America. A review of It’s Not About the Truth.

It’s Not About the Truth: The Untold Story of the Duke Lacrosse Case and the Lives it Shattered
by Don Yaeger with Mike Pressler
published by Threshold Editions (June 12, 2007)
Hdbk., 336 pgs.
ISBN-10: 1416551468
ISBN-13: 978-1416551461

The events relevant to the Duke Lacrosse case are well known to most Americans.¹  As of this writing, the players have been legally exonerated of all crimes and the prosecutor, who proceeded with criminal charges against them, former Durham District Attorney Mike Nifong, has been disbarred for ethics offenses. He now faces charges of criminal misconduct. The defendant, Crystal Mangum, who brought the false rape charges to the police’s attention, will face no sanction. Almost as soon as North Carolina Attorney General Roy Cooper declared the accused Duke Lacrosse players innocent,  he effectively did the same for Mangum, declaring “it is not in the best interest of justice.” It is unclear whether the Reverend Jesse Jackson will fulfill his pledge to pay for Ms. Mangum’s college tuition, “regardless of the outcome of the trial.”

It’s Not about the Truth: The Untold Story of the Duke Lacrosse Case and the Lives it Shattered is an inside account of the events surrounding the alleged rape. Its authors are Don Yaeger, a former writer for Sports Illustrated; and Mike Pressler, the former head coach of Duke’s Lacrosse team. Pressler was used as a scapegoat by the Duke administration for his players’ alleged offenses. He was forced to resign by the Duke Athletic Director Joe Alleva, who told him, despite compelling evidence that the alleged crime had never taken place, that “it’s not about the truth any more.” Yaeger’s book is written clearly and is neatly divided into 27 chapters which detail the key events and participants.  For the most part, It’s Not About the Truth is a remarkable survey of the allegations against the Duke players and the ensuing controversy. Its insights illuminate problems in the American legal system more insidious than the “race” issue the media has focused upon.

The Accusers

Shortly after accusing Duke players (the number accused fluctuated wildly) of raping her, Crystal Gail Mangum was portrayed in the Raleigh News & Observer as a “caring mother and hard worker” who stripped to pay for her college education and to feed her children. The Raleigh News & Observer had no evidence to substantiate these assertions. According to her employer, “Fats” Thomas, Mangum was a prostitute who “was stripping as advertising for hooking.” (51) Mangum initially failed to land a position at Fat’s club because she stole the taxi of a cab driver client after performing services “in excess of stripping and lap dances.” Her children were raised by her parents and she rarely saw them. (50) It is doubtful Mangum was enrolled in college. She had a history of mental illness and abused drugs.

Ten days after Mangum claimed she was raped and sodomized, she was back at “Fats Thomas’” strip club performing her usual routine. “She wasn’t hurt, Fats said. She wasn’t upset . . . she was completely normal.” Later that week, she was fired (again) for providing excessive services to Fats’ customers. When DNA samples were taken from her underwear as part of the investigation of her allegations, genetic residue from at least four men was found, not including that of her boyfriend.

The second stripper, Kim Roberts, was an opportunist with a marginally less dodgy background than that of Mangum; however, Roberts disappeared from the media spotlight after writing to a PR firm requesting they help her “spin this to [her] advantage” because she “didn’t want this opportunity to pass [her] by.” She told the Associated Press, “Why shouldn’t I profit from [this]?  I would like to feed my daughter.” She stopped talking to the press when she found out that they would no longer pay for interviews.

Durham Police

While much of the media attention has focused on Durham District Attorney Mike Nifong, the Durham police department’s lack of professionalism has hardly been mentioned. According to Yaeger, the sergeant in charge of the investigation, M.D. Gottlieb, had a pattern of harassing Duke students.  Yaeger gives several examples of Duke students being treated less generously than their Durham counterparts. Yaeger alleges the Durham police department orchestrated media leaks to embarrass the players; and by publication of a “vigilante poster” and other means, effectively declared the players to be guilty before due process was fulfilled. (81) While Yeager’s case here is less convincing, there can be little doubt that the Durham police department kowtowed to local pressure and contributed to the frenzied environment, making possible a modern lynching of the players. 

Mike Nifong

Durham District Attorney Mike Nifong is the principal villain in Yaeger’s account.  From the outset, Nifong exploited the media, accusing the Duke players of hiding behind a “Blue Wall of Silence” even before any investigation had taken place. By March 31 he told the Raleigh News & Observer he’d given “in excess of fifty interviews.” He told MSNBC that, “[He] felt that this was a case that we needed to make a statement, as a community, that we would not tolerate this kind of behavior here in Durham.” He told the Raleigh News & Observer, “I would like to think that somebody who was not in the bathroom has the human decency to call up and say, ‘What am I doing covering up for a bunch of hooligans?’”

Nifong was quick to play the “race card,” telling USA Today that, “There’s been a  feeling in the past that Duke students are treated differently by the court system . . . I’m not going to allow Durham’s view (sic) in the minds of the world to be a bunch of lacrosse players (sic) at Duke raping a black girl from Durham.” He told the New York Times: “The thing that most of us found so abhorrent and the reasons I decided to take it over myself, was the combination ganglike rape activity accompanied by the racial slurs and general racial hostility.”

He played the class card: “There was a feeling that Duke students’ daddies could buy them expensive lawyers and that they knew the right people.” 

In fact, the Duke players initially cooperated with the police investigation, but after being repeatedly set up by leaks to the media, several players secured legal assistance. Nifong immediately went on ESPN, declaring “one would wonder why one needs an attorney if one was not charged and had not done anything wrong.” The irony here, as Yaeger points out, was that Nifong himself immediately secured legal counsel as soon as he was accused of misconduct. 

When DNA tests proved that the players' DNA was not among those samples found on Mangum’s underwear, Nifong resorted to theatrics and threats to buttress his case — much to the delight of the media. On The Abrams Report, he dramatically demonstrated how the victim was supposedly choked, “elaborating on how she was grabbed from behind and struggled to breathe.” He didn’t bother to mention that he had yet to discuss the facts of the case with her. When asked how he could describe what had transpired without having spoken to the victim, he declared it “was because her experience was so traumatizing he did not want her to have to recount what happened.” 

As late as June 19, Nifong would tell Newsweek that:

None of the ‘facts’ I know at this time, indeed, none of the evidence I have seen from any source, has changed the opinion that I expressed initially . . . [I]f in the meantime you and other journalists want to continue your speculations in the competition to come up with the most sellable story . .  . then please spare me the recriminations when you get things wrong, as you inevitably will.

In Yeager’s best investigative work, he looked into Nifong’s election campaign, which was ongoing with the investigation. He argues convincingly that Nifong’s prosecution strategy resulted from his need to secure the votes of Durham’s black community. While it can’t be proven conclusively, it’s probable that Nifong delayed pursuing the investigation of Mangum’s allegations and manipulated the media to surmount a 17 percent deficit in the polls. His inflammatory racial language baited Durham’s large black community into supporting him and his insistence upon prosecuting the bogus allegations conveyed to the black community that their security lay with him. Sure enough, Nifong pocketed the black vote and the election.

The Media²

The media in general behaved abominably, abusing its power to represent events by substituting objectivity for insinuation. This enabled the mediocre Nifong to orchestrate his reelection campaign with maximum effectiveness. Yaeger believes that the Durham police would tip off the press, enabling reporters and photographers to “ambush” the players and to put the “rapists’” photos in the public domain. (73) Reporters Samiha Khanna and Anne Blythe of the Raleigh News and Observer were the first to invent the tale of “Crystal,” portraying her as a hard-working mother and victim of racist monstrosity.

Among the national media, the award for irresponsibility goes to CNN’s Nancy Grace, who used the debacle to perfect the art of the “media lynching.” Grace immediately began referring to the players as rapists and stoked up her audience with lines such as, “I’m so glad they didn’t miss a lacrosse game over a little thing like gang rape.” When one guest, Kevin Miller, a reporter with WPTF radio in Durham, pointed out that no one really knew what evidence Mike Nifong had, Grace responded:

Well, I’m glad you have already decided the outcome of the case, based on all of the defense filings. Why don’t we just sail to Nazi Germany, where we don’t have a justice system and a jury of one’s peers.

Grace featured professional “victim’s advocate,” Wendy Murphy (of a Boston victims advocacy group), who concocted far-fetched reasons for disputing any evidence which might exonerate the Lacrosse players. The most compelling reason for holding the Duke players guilty, Murphy argued, was “what they didn’t do.” According to this extraordinary logic, the Duke players must be guilty because they didn’t engage in wild media-baiting statements, as did Nifong.

I mean . . . it’s the fact that they take an awful long time for the defense to come out and say anything meaningful . . . and the silence is deafening . . . What they did was clam up and stay let’s stick together so we can get away with this.

When DNA evidence seemed to exonerate the players, Murphy argued that the Duke players must have been “rape experts,” thus taking pains to not permit their DNA to be found in the victim. This was so obvious to Murphy that she said Crystal “deserved extra credibility” precisely because there was no DNA evidence.

The Duke Administration

The principal figures involved from the Duke administration were Athletic director Joe Alleva,  President Richard Brodhead, and Vice President John Burness. Alleva is originally portrayed as a figure sympathetic to the Duke players, though his assurances to Pressler and the team would be shown to be worthless. Alleva led Pressler to believe that if the players could be exonerated, then the situation would be resolved. As media pressure on the University and the students escalated, Alleva chose to ignore the exonerating evidence and essentially fired Pressler, declaring infamously that the situation “was no longer about the truth.”

Firing Pressler benefited Alleva and the Duke administration for several reasons. First, it generated the appearance that the players were guilty. Second, it isolated the incident by implying that Pressler had been behind the stripper party by running his team in a reckless fashion. Finally, it allied the Duke administration with Nifong, who was at the moment commanding the local (and to a less degree national) media.

Pressler, upon being ordered to resign, confronted Alleva, asking him who was really behind the firing, “you or Brodhead.”

[Alleva] hesitated and said, “I’m firing you.” In my mind I thought, even at the very end he can’t tell me the truth.

Yaeger is sharply critical of Burness, accusing him of manipulating the press with off the record comments. He also accuses Burness and Brodhead of siding with Nifong; however, these accusations are poorly documented. The chapter on Brodhead is very unsatisfactory. Much of it is spent praising Brodhead’s Ivy League achievements (he was a Dean at Yale). While It’s Not About the Truth implies that Brodhead was obviously and egregiously negligent for his lack of support of the players, Yaeger doesn’t draw this conclusion. Instead he has recourse to Duke Basketball coach Mike Krzyzewski, who said broadly — and tepidly — something to the effect that the University might have done a better job supporting “our kids.”

While Brodhead and Burness declined to be interviewed for the book,³ it is highly unlikely Burness and Alleva would have done anything significant without Brodhead’s approval. Had Alleva backed Pressler, he could have easily been turned into a second scapegoat; and yet firing Pressler could hardly have endeared him to Duke’s athletic community, which he was supposed to lead. There is more to this story, which Yaeger hasn’t uncovered.

The Duke Faculty

On April 6, 2006, 88 Duke Professors (constituting 20 percent of the undergraduate faculty), following Nifong’s orchestration of the media, signed a letter titled “We’re Listening” which was published in the student newspaper. The ad declared that the professors were

. . . listening to . . . students who know themselves to be objects of racism and sexism, who see illuminated in this moment’s extraordinary spotlight what they live with everyday . . . These students are shouting and whispering about what happened to this young woman and to themselves.

One of the 88 faculty members, Houston A. Baker, a Professor of English and African American studies, clarified what the ad meant (at least to him) in a letter to the administration:

It is virtually inconceivable that representatives of Duke University’s Athletic Department would allow its lacrosse team to engage in regular underage drinking and out of control bacchanalia . . . Young white, violent, drunk men among us — implicitly boated by our athletic director and administrators — have injured lives . . . What is precipitously teetering in the balance at this point during weeks marked by inaction and duck–and–cover from our designated leaders is, well, confidence . . . There can be no confidence in an administration that believes suspending a lacrosse season and removing pictures of Duke Lacrosse players from a web page is a dutifully moral response to abhorrent, sexual assault, verbal racial violence and drunken white male privilege loosed amongst us. (sic throughout)

Another faculty member, Karla FC Holloway, following the “Wendy Murphy” school of evidence interpretation, resigned after Brodhead decided to invite indicted playersReade Seligmann and Collin Finnerty back to school. She then wrote an article in the Scholar and Feminist Online Journal, declaring:

At Duke University this past spring, the bodies left to the trauma of a campus brought to its knees by members of Duke University’s lacrosse team were African-American and women.

Holloway, whose son had been convicted of rape and the attempted murder of three others, was rebuked by Patricia Dowd, mother of player Kyle Dowd. Dowd asked how “any woman could be so cruel and callous and judge a whole class of individuals without any facts?“ Holloway responded to Dowd’s letter by accusing her of having an “impoverished spirit and intellect.” She was joined by Duke Professor Houston Baker, who emailed Ms. Dowd, writing:

LIES! You are just a provocateur on a happy New Years Eve trying to get credit for a scummy bunch of white males! You know you are in search of sympathy [sic] for young white guys who beat up a gay man in Georgetown, get drunk in Durham, and lived like ‘a bunch of farm animals’ near campus . . . happy [sic] new year to you . . . and forgive me if your [sic] really are, quite sadly, mother of a ‘farm animal.’

It wasn’t until January 2007, as public opinion began to question Nifong’s rush to indictment, that the Lacrosse players found public support on the Duke campus from their professors. 17 faculty members of the Economics Department wrote a letter to the student newspaper noting the irregularities in the proceedings against the Lacrosse players.⁴  They then wrote that we “welcome all members of the lacrosse team, and all student athletes . . . to the classes we teach.”

Shortly afterwards, a second letter by the “Group of 88” was published in the school newspaper in response to the letter from the Economics faculty. The letter claimed that the original “Open Letter to the Duke Community” had been misconstrued as “a comment on the alleged rape . . . or the specific students accused.” Worse, the authors wrote, “it has been read as rendering a judgment on the case.” The “Group of 88” now said that the point of the letter had been merely a “call to action [and dialog] on important, longstanding issues on and around campus . . ..”

Yeager ridicules the second letter from the “Group of 88.”  This is “Revisionist History,” says Yeager, and cites a pundit who declared that such a claim is the equivalent of someone writing a letter denouncing the treasonous attitudes of Jews around the time of the Dreyfus case — but of course insisting this has nothing specifically to do with Alfred Dreyfus. FOX News host Bill O’Reilly agreed, trying repeatedly to get members of the “Group of 88” to explain why none would apologize for the ad — or even be interviewed about it. He emailed all 88 individually and got no response. Lacrosse player Kyle Dowd pointed out that while the professors claimed they wanted to “start a dialog,” “Now you refuse to speak to the media, you refuse to speak to us, you refuse to speak to other professors.” Because of the Professors' “Wall of Blue Silence,” [they’ve] actually decreased dialog about these topics. . ..”⁵ 

Lessons Learned and Unlearned

The strongest impression one takes from reading Yeager’s book is not of rage — though that is what Yaeger intends. While Pressler is an obvious victim of injustice, it is not obvious to what degree those associated with the related events may be assigned guilt. Nifong can hardly be blamed for pursuing the Lacrosse players aggressively — or at least at first. Having a reputation as a “tough DA” is generally what gets you elected and had the players been guilty, he would no doubt have been criticized for not being tougher. The same can be said for the Durham police department, whose “manipulation” of the press is probably pretty standard behavior. Unethical — sort of, but much in the same way that hiring strippers is unethical.

Duke President Brodhead is an obvious target for criticism — and it is bizarre how Yaeger tiptoes around this; however, here too, it’s not obvious that Brodhead should have put Duke University’s reputation on the line for an athletic coach and its athletes. Had Brodhead immediately targeted Nifong (before knowing the facts), he would have been guilty of the same “rush to judgment” which compromised those in the media and Duke faculty who spoke without regard to facts. Moreover, it is not clear that had Brodhead publicly intervened, that anything positive for the players would have resulted. It certainly would have raised the profile of the case, but this might well have played into Nifong’s hands.

Moreover, Brodhead’s involvement would have enabled the “Group of 88” and “yahoo” commentators such as Nancy Grace to exaggerate their “exposes” further by alleging a “Duke conspiracy” of some sort. By confining the events surrounding the Lacrosse team to the athletics department and not directly involving himself in the day to day events, Brodhead, to some degree, prevented the Al Sharptons and similar “advocates” from exploiting events to further their agendas at Duke University (though obviously Sharpton would have found many willing faculty members to assist him).⁶  Yeager understandably wants the University to adopt the US Army Ranger motto, “No Man Left Behind” — which is why he repeatedly makes references to “the kids” and portrays the University as having abandoned them. It’s possible the ensuing spectacle resulting from Brodhead’s hasty intervention would have served to create another Mogadishu.

There are three lessons to be learned from the Duke debacle. First, and most importantly, the price of justice in the United States.  Lacrosse player David Evans, upon being exonerated by North Carolina Attorney General Roy Cooper, declared to the media that most families would not have been able to afford the legal costs to defend themselves. Yaeger gives no precise figure, but hints that legal costs for the three accused probably exceeded a million dollars per player — and might have been as high as five million. This is clearly the principal lesson to be learned, and it has little to do with the media’s favorite issue, race. A black man or woman falsely accused of a crime in Yonkers, New York, might run into the same problem that the Lacrosse players ran into in Durham. Without money, it is easy to be railroaded through the legal system, even if one attends an elite university, such as Duke.

Second, the “due process of law,” because of its immense cost, has become a means of inflicting suffering. Judge Roy Pearson, in his 67 million dollar lawsuit against the South Korean couple who allegedly lost a pair of his pants, probably didn’t expect to win; however, he knew he could use the cost of “procedure” to force the Korean couple into bankruptcy. According to the South Korean couple’s attorney, their legal expenses will exceed one hundred thousand dollars.⁷

It’s in his abuse of procedure that Mike Nifong’s greatest maliciousness lies. Nifong was fully aware that by attacking the Lacrosse team “scattershot” and through the media, he would force all 47 to mount a legal defense. While Nifong would eventually — and at immense expense — be successfully accused of violating procedural rules himself, “due process” became a way in which he gave himself multiple opportunities to “nail” the Lacrosse players. The ruinous costs of defending themselves became greater with Nifong’s public racial and class theatrics, which forced the players to appease not only the law but public opinion.

The third lesson, lost to the Nifongs, Graces, Murphys, Bakers, and Holloways, is that justice, in the end, is an individual thing. Advancing a social cause may ingratiate one with a political constituency, but in the end it is the careful application of the law combined with attention to justice that is best for individual men and women of whatever ethnicity. The hysterical posturing of the Graces, the Murphys and Bakers, however, should be of no surprise. The upper middle class audiences which they entertain may very well be able to afford the cost of exploiting the lengthy (and porous) procedure process to their own advantage, just as Nifong did. The O.J. Simpson case was an example of this. However, procedure exists to protect the majority of the population who, as the Duke case clearly indicates, can no longer afford it. Weakening the procedural process further by demanding “outcomes” instead of attention to individual justice, benefits only the wealthy.

Scapegoating Nifong?

The rush to implicate Mike Nifong as the culprit behind the Duke debacle is, in the broader scheme of things, almost as bad as the scapegoating of Mike Pressler. North Carolina Attorney General Roy Cooper was quick to blame Nifong — and nearly as quick to announce that he wouldn’t pursue Mangum and Roberts, who were responsible for initiating the entire mess. Duke President Brodhead eventually called for Nifong to remove himself from the case and has said nothing about the “Group of 88.” The media has hailed the decision to disbar Nifong as a triumph for the players, and said little about the crushing legal fees which make this at best a pyrrhic victory. Rather than examining the case closely, Nifong has become a convenient scapegoat for avoiding the real lessons of the Duke debacle — and the Graces and Murphys have no doubt moved on to more glamorous scandals. Abuse of procedure and the cost of justice is the real story behind the Duke debacle.⁸  By mustering the resources and standing up to him, the Duke Lacrosse players exposed these issues for the public to see. Now, it appears, Mike Nifong is being used, once again, to cover them up.

Endnotes

1. On March 13, 2006, members of Duke University’s Lacrosse team requested two strippers from Allure Escort Service to attend a party at one of the player’s houses that night. The strippers arrived between 11:15 and 11:50 pm. They performed between 12:00 and 12:04 am. Between 12:05 am and 12:15 am the women locked themselves in the bathroom and between 12:15-12:25 am they left the house. Later that evening, “Crystal” would allege she had been raped. Two days later, “Crystal” would identify five Duke players as her assailants. On March 24, the press would report that members of the Duke Lacrosse team were being investigated for an alleged rape. On March 27, District Attorney Mike Nifong would address the media for the first time, accusing the Duke team of “stonewalling” and showing “contempt for the victim . . . based on her race.” On March 28 Duke Vice President Brodhead suspended the lacrosse team until the case has a “clearer resolution of the legal situation.” Later that day Nifong refers to the team as hoodlums, and warns he may bring “aiding and abetting charges against some of the players.”  On March 29, Duke Faculty members meet with Brodhead and urge him to fire coach Pressler, disband the Lacrosse program, cancel the season, and suspend the entire team. On April 5, the New York Times begins publishing accused players’ biographies. Duke cancels lacrosse season and forces Coach Pressler to resign. April 6: 88 Members of the Duke Faculty publish ad, “What does a social disaster sound like,” which appears in Duke's Chronicle. April 10, Defense Attorneys publicly announce that DNA testing found no match between players tested and accused. April 16, Jesse Jackson promises to pay for the rest of “Crystal’s” tuition, regardless of the outcome of the case. April 17, Collin Finnerty and Reade Seligmann are indicted and charged with first-degree forcible rape, first-degree sexual offense and kidnapping. Bail is set at 400,000 dollars for each player. May 15, a third player, David Evans, is indicted on the same charges by a grand jury. December 22, in lieu of multiple conflicting testimonies by “Crystal” and the lack of DNA evidence, prosecution drops rape charges against the players. December 28, Vice President Brodhead asks Nifong to relieve himself of the case. State bar files complaint against Nifong, accusing him of ethics violations. January 10: 17 members of Duke’s economics department publish letters to Duke newspaper apologizing for other Duke faculty members’ prejudice in publishing the initial article on the lacrosse team. January 16: 87 Duke faculty publish a letter in the Duke Newspaper defending their ad published in April. They claim the ad did not assume the players’ guilt and was not published as a reaction to the charges. January 24: State bar accuses Nifong of lying at least five times (including suppressing DNA evidence). April 11, all charges dropped.

2. It should be noted there was some outstanding media work. K.C. Johnson of Brooklyn College put together a brilliant web site, “Durham in Wonderland,” which is probably the best account of the events surrounding the players. Duke Student Newspaper columnist Stephen Miller endured much abuse in his attempt to get the truth out. FOX News also acquitted itself well — particularly Greta van Sustern and Bill O’Reilly. 

3. According to Yaeger, Burness told him that his feelings on the matters were too partisan.

4. To the best of my knowledge, only one Duke law professor registered his criticisms of Nifong’s proceedings publicly.

5. One student, Chauncy Nartey, deserves special mention. As Nifong’s media campaign escalated, a Duke student got in on the action. On March 27 the “student activist” sent Pressler an email:

[S]ome things are more important than winning a few games. End the season until the alleged rapists are found. You’ll be a better coach for it.

The email was followed up immediately by another:

What if Janet Lynn (Pressler’s daughter) were next???

When Pressler reported the rape threat to the Dean of Students, the Dean told Nartey, “don’t do it again.”

Nartey would write a smarmy apology to Pressler two months later and when asked for an interview for Yeager’s book, would threaten Yeager with a lawsuit “if his words were mischaracterized.”

The reader can decide if this is the sort of dialog the Group of 88 sought to inspire.

6. Larry Summers’ very public attempt to reform Harvard University failed in part because of opposition from Harvard’s faculty.

7. Judge Pearson did all his own work — thus presumably getting some use out of his law degree. His bill, submitted to the court as “attorney’s fees,” exceeded one hundred thousand dollars, which he hoped to collect from the Koreans. He was able to use the threat of litigation as a means of forcing the Korean couple to offer him over $12,000 as a means of forestalling further legal expenses! Of course it’s unclear how Judge Pearson could have performed his own job while clearly spending the bulk of his time harassing the Koreans.

8. No more pressing area of the law in this regard may be found than that of child custody law. Every day throughout America, “non-custodial” parents are railroaded through a legal “system” unworthy of the name. To thwart a non-custodial parent from seeing his child is no more difficult than appealing to “procedural rights:” simply escalate the procedural cost of the parent paying child support and you will win by default — in the end, child support will recoup your losses.  False allegations? These may be sustained indefinitely by endless procedural absurdities — and in fact the custody system encourages them: an allegation not refuted is one sustained, and a non-custodial parent who has not “refuted” a false allegation may be more readily deprived of access to their children.

Book Reviews, Culture: Sports

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