Current Issues in Forensic Psychology 407 there had been at least 450 cases in 26 states in which eyewit- ness researchers had testified as experts (Fulero, 1993). It has been pointed out that “no such problem of admissibility was raised in the 1950s when clinical psychologists began to tes- tify on mental disorders or when social psychologists first appeared to describe the debilitating personality conse- quences of segregation” (Loh, 1981 p, 332). One reason for the cool legal reception to eyewitness researchers is that the law requires particularized proof rather than general proof (e.g., average responses as shown by research), and the law is reluctant to assume that there is a one-to-one correspondence between potential unreliability of eyewitnesses (which is con- ceded) and its actual impact in a particular trial (which must be proven). Another issue is that many courts have assumed that awareness of the fallibility of eyewitness evidence is already within the “common knowledge” of most jurors, leav- ing no need for expert testimony (Brigham et al., 1999). The typeof issuestudied mayalso make a difference. Wells (1978, 1993) asserted that psychologists should concentrate on studying system variables, that is, factors that are change- able within the system (e.g., police procedures, interrogation techniques, fairness of lineups), rather than estimator vari- ables, whose impact in any particular situation can only be estimated (e.g., level of stress, weapon focus, race). Wells as- serted that because of their potential usefuless for improving procedures, the results of system-variable research would be more readily accepted by the legal system than would estimator-variable research. It remains to be seen whether the legal system will become more receptive in the future to expert testimony about the memory of eyewitnesses, or whether the results of eyewitness research find their way into the legal sys- tem by other means (e.g., via science-translation briefs). Clinical Forensic Evaluations Little research was directed toward improving clinicians’ evaluations for the courts until the 1980s. This changed dramatically across the next 20 years, heralded by seminal works published early in the 1980s. Among these were Monahan’s (1981) treatise summarizing the serious limits of our abilities to assess and predict violent behavior, the first book to summarize what we did and did not know about competence to stand trial as a legal and forensic assessment issue (Roesch & Golding, 1980), the publication of a system- atic model for the future development of instruments to as- sess a variety of legal competencies (Grisso, 1986), and the first comprehensive texts on the full range of forensic psy- chological evaluations for the courts in criminal, civil, and juvenile cases (Melton, Petrila, Poythress, & Slobogin, 1987; Weiner & Hess, 1987). The importance of improving psychologists’ abilities to assess the potential for future violence among offenders and persons with mental illnesses was driven also by legal cases during the 1980s. Most notable among these was Barefoot v. Estelle (1983), in which the U.S. Supreme Court acknowl- edged experts’ inability to provide reliable predictions but, ironically, determined that they should continue to be con- sulted by the courts. Several large-scale research projects to improve our abilities to assess the risk of future violence began in the 1980s and had a major impact on practice when their results emerged in the 1990s. Among these were the work of researchers who developed and validated compre- hensive violence risk assessment tools to provide estimates of likelihood of reoffending among prisoners (e.g., Quinsey, Harris, Rice, & Cormier, 1998), likelihood of future violence related to psychopathy (Hare, 1996), and likelihood of vio- lence among persons with mental disorders after their release from psychiatric hospitals (Steadman et al., 1998). Research to improve our conceptualization and assess- ment of abilities related to legal competencies grew exponen- tially throughout the 1980s and 1990s. Reviews of research on competence to stand trial (Roesch, Zapf, Golding, & Skeem, 1999) describe the development of important and basic information regarding the legal process for determining competence, as well as the validation of structured assess- ment tools for obtaining relevant psycholegal information on defendants in such cases (e.g., Poythress et al., 1999). Similar advances were made in substantial research projects culminating in data and assessment tools to improve evalua- tions of competence of patients to consent to treatment (e.g., Grisso & Appelbaum, 1998). Child and Adolescent Psycholegal Issues Research advanced in the 1980s and 1990s in a number of areas pertaining to children’s capacities related to psycholegal questions. Among the most extensively researched of these questions was children’s capacities to offer reliable testimony as eyewitnesses or as victims (e.g., Ceci & Hembrooke, 1998; Ceci, Toglia, & Ross, 1987). By the 1990s, developmental and experimental psychologists were able to provide signifi- cant information to courts regarding not only children’s capacities to testify but also methods of investigation and questioning that would reduce the likelihood that children’s reports would be contaminated by their experiences between the event and the trial. Children’s capacities to make decisions about matters af- fecting their welfare became a major issue in the courts in the late 1970s in the context of debates about youths’ choices concerning abortion (e.g., Bellotti v. Baird, 1979), medical 408 Forensic Psychology treatment (e.g., Parham v. J.R., 1979), and waiver of Miranda rights (e.g., Fare v. Michael C., 1979). Calls for research to address these issues (e.g., Melton, Koocher, & Saks, 1983) were answered by many researchers, and the need for further research in this area increased as more punitive delinquency laws of the 1990s strengthened the argument that youths had to be competent to stand trial (Grisso & Schwartz, 2000). FORENSIC PSYCHOLOGY IN THE TWENTY-FIRST CENTURY While we focused our attention on three areas above, the full range of topics that now fall under the rubric of forensic psychology is impressively broad. To illustrate, the second edition of The Handbook of Forensic Psychology (Hess & Weiner, 1999) contains sections on applying psychology to civil proceedings, applying psychology to criminal proceed- ings, communicating expert opinions, intervening with of- fenders, and professional issues (legal, ethical, and moral considerations; training in forensic psychology and the law). Among the civil proceedings discussed are mediating domes- tic law issues, personality assessment, educational disabili- ties, and civil competency. Among the criminal proceedings covered are assessing dangerousness and risk; evaluating eyewitness testimony; assessing jury competence; recom- mending probation and parole; assessing competency to stand trial, diminished capacity, and criminal responsibility; interacting with law enforcement; the “state of the art” of polygraph testing; and forensic uses of hypnosis. The section on interventions includes discussions of punishment, diver- sion, and alternative routes to crime prevention, substance abuse programs, psychotherapy with criminal offenders, and diagnosing and treating sexual offenders. Research is currently being carried out within each of these areas, and the results are reported regularly in the foren- sically oriented journals mentioned earlier, as well as in mainstream psychology journals and, less frequently, in law reviews and other legal journals. In addition, many psycholo- gists now take an active role in attempting to apply research findings and other relevant psychological knowledge to the legal system. In addition to the wide range of situations involving clinical psychological evaluations, these efforts may include writing research-based articles designed to in- form both attorneys and social scientists, delivering expert testimony, creating science-translation briefs, consulting with attorneys, and making presentations as part of continuing- education programs for attorneys and judges. The future of forensic psychology looks bright, as com- munication between leaders in both fields appears to be increasing in frequency and understanding. 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FAGAN 413 WHAT IS SCHOOL PSYCHOLOGY? 413 Demographic Descriptions 413 Training and Credentialing 413 Employment Characteristics and Services 414 Historical Periods Defined 414 THE HYBRID YEARS 414 Factors Contributing to the Origins of Practice 414 Professional Developments (1890–1920) 417 Emergence of School Psychology as a Distinct Field (1920–1940) 418 Emerging Symbols of Professionalization (1940–1970) 420 THE THOROUGHBRED YEARS (1970–PRESENT) 422 Organizational Development 423 Literary Development 424 Training Development 424 Credentialing Development 425 Practice Characteristics 425 Overview 426 A COMMENT ON THE FUTURE 426 ADDITIONAL RESOURCES 427 REFERENCES 428 WHAT IS SCHOOL PSYCHOLOGY? School psychology is an applied psychology specialty that blends the knowledge bases of education and psychology into a professional practice that delivers services to clients of vari- ous ages, primarily those of school age (preschool to college), in a variety of settings, primarily public and private elemen- tary and secondary schools. School psychology can be further defined along several dimensions, including professional as- sociation definitions, demographics, training, credentialing, employment characteristics, and services. A career publica- tion states that “school psychologists work directly with pub- lic and private schools. They assess and counsel students, consult with parents and school staff, and conduct behavioral intervention when appropriate” (American Psychological Association, 1998, p. 7). The Division of School Psychology (Division 16) within the American Psychological Association (APA) describes itself as composed of scientist-practitioner psychologists whose major professional interests lie with children, families, and the schooling process. The National Association of School Psychologists (NASP) describes school psychologists as members of a team with educators, parents, and other mental health professionals who seek to ensure that children learn in safe, healthy, and supportive environments. A broad definition of school psychology appears in the Peti- tion for Reaffirmation (1997). Demographic Descriptions Estimates are that there are at least 30,000 school psycholo- gists in the United States, perhaps constituting one-third of all school psychologists on earth (Oakland, 2000). Prac- titioners in the field are approximately 70% female, pre- dominantly Caucasian (at least 90%), have a median age of about 41 to 45 years, and have a median of 11 to 15 years of experience. School-based practitioners work within a psychologist-to-schoolchildren ratio of 1 to 1,800–2,000. Training and Credentialing Practitioners are prepared in more than 200 graduate-level school psychology programs. The programs are accredited by one or more of the following agencies: the APA (doctoral pro- grams only) and the National Council for Accreditation of Teacher Education (NCATE; master’s, specialist, and doctoral programs), and they are approved by state departments of edu- cation. Programs exist in departments of psychology in colleges of arts and sciences as well as various departments within collegesofeducation(e.g.,departmentsofspecialeducation,ed- ucational psychology). At least two-thirds of all school psy- chologists hold a specialist degree (EdS) or its equivalent (master’s degree plus 30 semester hours) or a higher degree; ap- proximately 20% to 25% hold a doctoral degree (EdD, PhD, PsyD). Specialist-level programs typically require 60 to 70 414 School Psychology semester hours, while doctoral programs typically require 100 or more. Both degrees require the equivalent of at least one school year of supervised internship (a minimum of 1,200 hours at the nondoctoral level and 1,500 hours at the doctoral level). School psychologists are granted practice credentials (cer- tificates or licenses) by each state’s department of education (SDE) and/or by a separate state board of examiners in psy- chology (SBEP). The SDE credentials school psychologists for practice in the settings under its jurisdiction, typically all public schools but also possibly private schools, correctional schools, and residential schools. The SBEP credentials prac- titioners, often referred to as health service providers, for practice in settings under its jurisdiction, typically all non- school settings within the state (e.g., mental health centers, hospitals, independent private practice). In some states the jurisdictional authority is less distinct. Employment Characteristics and Services School psychologists work predominately in school settings (at least 80%), under 9- or 10-month contracts (180–200 days). In 1999, their average salary was $49,000 per year.As school district employees, most are subject to the district’s conditions and receive benefits and retirement packages similar to those of other district employees. Other school psychologists work in a variety of nonschool settings. Among them, 3% to 5% work full-time in private practice, and 3% to 4% in colleges or universities. The referrals most commonly made to school psycholo- gists come from children in the elementary school grades and are more often males than females.The referrals are associated with learning and behavioral difficulties that teachers and/or parents often suspect are related to one or more categories of disability within the regulations of the state education agency. Surveys of practitioners have consistently revealed that they spend at least 50% of their time in psychoeducational assess- ment activities related to special education referrals, per- haps 40% of their time in consultation and direct intervention activities, and the remaining 10% in research and evaluation, in-service instruction, and administrative duties. Historical Periods Defined Although derived from similar origins and early develop- ments, contemporary school psychology is a specialty dis- tinct from clinical, counseling, and educational psychology. The historical development of school psychology has been described as consisting of two broad periods, the Hybrid Years (1890–1969) and the Thoroughbred Years (1970– present) (Fagan & Wise, 2000). During the Hybrid Years, school psychology was often a blend of educational and psy- chological practice; its dominant role was assessment to meet public education’s need for diagnoses for special class place- ment. Even in the latter decades of this period, school psy- chology was a mix of practitioners trained and certified in various fields (e.g., clinical psychology, teacher education, and guidance counseling) as well as many whose training and experience were specifically in school psychology. The Thoroughbred Years period differs from the previous period because of the rapid growth in the number of training programs, practitioners, and state and national associations, the expansion of literature, and increasing professional regu- lation from forces within and outside of the field. Collectively, these changes contributed to a stable professional entity known as school psychology. Since 1970, school psychol- ogists have been more consistently employed in positions titled “school psychologist”; they work in states offering school psychology credentials to those who have completed training programs specifically in school psychology and accredited as such and whose trainers have been school psy- chologists. This greater uniformity has been modal in the Thoroughbred Years, although it could be observed in more advanced locales in the latter Hybrid Years, especially in urban and suburban areas (Mullen, 1967). The Thorough- bred period was not achieved simply because of an identity made possible by more purely bred school psychologists. The Hybrid Years had many persons who championed the cause and identity of school psychology despite their own backgrounds in clinical and educational psychology, teacher education, and guidance counseling. Among the nota- bles were Harry Baker, Jack Bardon, Ethel Cornell, Susan Gray, Leta Hollingworth, Bertha Luckey, Grace Munson, Frances Mullen, T. E. Newland, Marie Skodak, and Percival Symonds. THE HYBRID YEARS The practice of school psychology did not start abruptly. Several factors contributed to the circumstances under which psychological services to schools emerged. Factors Contributing to the Origins of Practice Era of Reform Several factors led to the origin of school psychology as a distinct discipline. Paramount among these was a post–Civil War era of reform marked by the rise of juvenile courts, the enactment of child labor laws, the growth of institutions The Hybrid Years 415 serving children, the beginnings of the mental health, voca- tional guidance, and child study movements, and the enact- ment of compulsory school attendance laws for children. Collectively, these efforts reflected the improving status of children and youth in America and a growing commitment to the viewpoint that the welfare of our children was closely related to the long-term improvement of our society. Compulsory Schooling Compulsory schooling laws significantly influenced the con- ditions under which school psychological services devel- oped. Over the course of American history, the responsibility for schooling had passed from parents in the home, to schooling outside of the home, and eventually to formally established, compulsory schooling. Even in the absence of compulsory attendance laws, school enrollments grew throughout the nineteenth century. The attendance reflected a growing need for education to help children and youth meet society’s demand for educated employees to fill newer and more technologically demanding jobs. It also reflected the need to inculcate a sense of moral values and character to better ensure the survival of the nation. The concern for na- tional survival was related to heightened U.S. immigration during this period. These and other forces spurred the com- pulsory schooling movement, and by 1920 all states had en- acted such legislation. Thus, during the period 1890–1920, increasingly large numbers of children were thrust upon the public schools, many of whom had never before attended school in America or elsewhere before coming to America as immigrants. Between 1890 and 1930, public school en- rollments increased from 12.7 to 25.7 million students, with secondary school enrollment increasing from 203,000 to 4.4 million. The average number of days in the school year increased from 135 to 173 (28%), and the average number of days attended increased from 86 (64% of 135 day year) to 143 (83% of 173 day year). Special Education The schools were not well prepared for such rapid change. The formal preparation of teachers was meager by contem- porary standards, accreditation of programs and teacher cre- dentialing were practically nonexistent, class sizes were large, facilities were often ill equipped and unhealthy, and large numbers of children had various mental, physical, and other disabilities that impaired their efforts to learn. Estimates of the number of children with disabilities were large. For example, Wallin (1914) estimated that 12 million pupils were handicapped by one or more physical defects (e.g., defective vision or hearing, adenoids, teeth, lungs). Such conditions quickly led to medical inspections for school entrance. Noting the presence of other disabilities related to school learning (e.g., intelligence, memory, speech, sensa- tion), Wallin called for psychological inspections as well. Wallin reasoned that if the child was to be compelled to at- tend school, then it was the state’s responsibility to provide conditions under which the child could learn the material the state required him or her to learn. Compulsory schooling, which led to the mass education of children, in effect created the conditions under which other forms of educational treat- ments would be needed for children who failed to profit from the regular educational program. Thus was advanced the con- cept and practice of special education and the groundwork for what would become a growing separation of regular and spe- cial education throughout the twentieth century. The growth of special classes, usually segregated from the mainstream of regular education, was gradual but persistent. Dunn (1973) indicates that special education enrollment grew from 26,163 in 1922 to 356,093 in 1948 and to 2,857,551 by 1972. Today more than five million school children are in special education. Rise of Experts Compulsory schooling thus created a major community set- ting, the school, within which psychologists could choose to work. This was as significant to the future of school psychol- ogy as the promise of the Community Mental Health Centers Act of the 1960s was to clinical and counseling psychology. Moreover, the conditions of the children placed demands on educators that would require the addition of specialized personnel in several fields, including school psychology. These fields would soon be referred to collectively as pupil personnel services and would include attendance officers, truant officers, social workers, guidance counselors, voca- tional counselors, school health workers including nurses and physicians, speech and language clinicians, and psycholo- gists. Schooling had not only become formalized outside of the home, but there were now various experts to assist an increasingly formally trained teaching force. Despite opposi- tion from the scientific psychology community, the emer- gence of psychological science during this period influenced the rise of experts in applied psychology. Applied psycholo- gists were part of a growing class of experts in many fields as knowledge expanded rapidly and one could no longer expect to manage the affairs of life without expert assistance. Real or illusory, this perception grew during the twentieth century, promoting the rise of psychological experts, specializations, and subspecializations. 416 School Psychology Child Study Movement Another potent factor in the origin of school psychological services was the child study movement. Influenced primarily by G. Stanley Hall, this movement served to sensitize parents and teachers to the importance of childhood and to the knowledge gained about children from research through observational and questionnaire methods. Hall was interested primarily in the normative aspects of the development of nor- mal children and youth. By the beginning of the twentieth century, he had supervised or conducted dozens of normative research studies that helped to define the typical or normal child. The child study movement had chapters in several states, and conventions were held on child study topics. Hall founded several professional journals and is credited with founding the American Psychological Association (APA) in 1892 (Ross, 1972). Educational Psychology Hall’s efforts and those of other psychologists of the period (e.g., E. L. Thorndike) fostered the emergence of educational psychology as a major field of psychological application. Educational psychology built upon the normative notions of child study and sought to provide educators broader under- standing of how children learn, how curricula could be more efficiently arranged, and how schools could be better orga- nized. Educational psychology also served to sensitize edu- cators and parents to the contributions that psychology could make in the mass education movement (see e.g., Cubberly, 1909; Thorndike, 1912). Clinical Psychology Another highly potent factor was the emergence of clinical psychology. Although related to the child study movement, the emergence of clinical psychology is credited to Lightner Witmer, and its orientation was primarily idiographic. Witmer is considered to be the father of clinical psychology, having founded the first psychological clinic in this country at the University of Pennsylvania in 1896 (McReynolds, 1997). Where Hall was concerned about the typical development of schoolchildren, Witmer was most concerned with diagnosing and intervening on behalf of children who did not thrive in the regular educational environment of the mass education exper- iment. Witmer’s efforts brought to the attention of educators and parents the importance of studying and designing inter- ventions for individual children with one or more atypical characteristics. He worked in school settings on occasion and received numerous referrals from parents and educators. By the early twentieth century, he was training persons to pro- vide these services on a limited basis to schoolchildren. Though perhaps the first person to practice school psychol- ogy, Witmer never held that title, nor did he originate the term. Rather, the term “school psychologist” appears to have its origins in the German literature, first translated into English in 1911 (Stern, 1911). Summary of Potent Factors In summary, among the most potent factors creating the con- ditions for school psychological services were the changing status of children, the emphasis on the importance of child- hood to saving adult society, and the central role of public schooling in that process. Indeed, almost every perceived failure or problem in society throughout the twentieth cen- tury led to curricular and other adjustments in our schools. These include food services for the poor, special reading pro- grams, pupil personnel services, alcohol, drug, and tobacco prevention programs, special programs for teen pregnancy, delinquency and dropout prevention, and special education. Even curricula in home economics and driver education can be seen as reflecting societal needs. In addition, the importance of children as emotional, as opposed to mainly financial, assets (see e.g., Zelizer, 1985) and the fact that they were housed for much of their childhood and youth in school buildings helped to create a new culture of childhood and adolescence that pervaded the twentieth cen- tury.Theemergence of adolescence as a formal developmental stage and recognition of the significance of peer groups are, in part, a function of the mass education movement. Formal entry into adulthood for most children became delayed until the late teen years or longer, and it was educational facilities that served as warehouses for children and youth until such entry. Needless to say, the growth of elementary enrollments would lead to growth in secondary enrollments, then growth in the postsecondary colleges and universities, technical schools, and other forms of education. With this formal structure in place, the post–World War II baby boom would accelerate these developments. Applied psychologists would follow this trend, and by the late twentieth century, school psychologists were employed in preschool, elementary, secondary, and postsecondary educational settings. The emergence of child study and clinical and educational psychology in the period 1890–1920 were symbiotic develop- ments with the emergence of mass education. They were in- strumental in advancing the organization of schools and their curricula and in drawing attention to the needs of atypical children through special educational programs. The disciples of pioneers like Hall and Witmer would bring together the [...]... Psychologist, 39, 976– 987 French, J L (1 986 ) Books in school psychology: The first forty years Professional School Psychology, 1, 267–277 French, J L (1 988 ) Grandmothers I wish I knew: Contributions of women to the history of school psychology Professional School Psychology, 3, 51– 68 References French, J L (1990) History of school psychology In T B Gutkin & C R Reynolds (Eds.), Handbook of school psychology (pp... University of Chicago Press Slater, R (1 980 ) The organizational origins of public school psychology Educational Studies, 2, 1–11 Stern, W (1911) The supernormal child: II Journal of Educational Psychology, 2, 181 –190 Symonds, P M (Ed.) (1942) [Special issue] Journal of Consulting Psychology, 6(4) Thomas, A (Ed.) (19 98) Directory of school psychology graduate programs Bethesda, MD: National Association of School... and action With this chapter we will frame the development of the field of community psychology in a historical and social context The history of community psychology is not just a history of professional developments but also a history of the interaction of social events and the development of community psychology The evolution of community psychology has been coupled with events in U.S history beginning... literature of professional school psychology 189 0–1 985 Washington, DC: National Association of School psychologists Fagan, T K., Gorin, S., & Tharinger, D (2000) The National Association of Schools Psychologists and the Division of School Psychology APA: Now and beyond School Psychology Review, 29(4), 525–535 Fagan, T K., & Sheridan, S (2000) Miniseries: School psychology in the 21st century School Psychology. .. (Cherniss, 1 989 ; McGhee, 1 984 ; Potasznik & Nelson, 1 984 ) Methodologies that most often require qualitative methods of analysis, such as participant-observation and the use of narratives, have been used to understand and describe social settings (Rappaport, 1995) In 19 98, K Miller and Banyard edited a special issue of the American Journal of Community Psychology (AJCP) dedicated to the use of qualitative... similarities to contemporary school psychology (Fagan, 1 987 ) Professional Developments ( 189 0–1920) In addition to the factors that led to the emergence of school psychology, several other professional developments between 189 0 and 1920 contributed to the discipline’s development Spread of Clinics Witmer’s clinical psychology and Hall’s child study stimulated the rise of clinics in hospital, residential... as a member subscription journal, and it has one of the largest circulations of all psychology journals The Division of School Psychology- APA founded Professional School Psychology (now School Psychology Quarterly) in 1 986 The division’s journal was an indirect outgrowth of its monograph series in the 1970s Both groups improved the content and size of their newsletters and provided other products in... psychologist Psychological Clinic, 15, 48 51 Kraus, T., & Mcloughlin, C S (1997) An essential library in school psychology School Psychology International, 18, 343–349 Loutit, C M (1939) The nature of clinical psychology Psychological Bulletin, 36, 361– 389 Maher, C A., Illback, R J., & Zins, J E (Eds.) (1 984 ) Organizational psychology in the schools: A handbook for professionals Springfield, IL: Charles... future (2nd ed., pp 355– 381 ) Bethesda, MD: National Association of School Psychologists Oakland, T D., & Cunningham, J (1999) The futures of school psychology: Conceptual models for its development and examples of their applications In C R Reynolds & T B Gutkin (Eds.), The handbook of school psychology (pp 34–53) New York: Wiley Petition for reaffirmation of the specialty of school psychology (1997, March... 1990s Also of interest to literary expansion in the United States was the founding of School Psychology International in 1979 and the Canadian Journal of School Psychology in 1 985 Numerous books on school psychology and related topics were published, including those that were revised periodically, for example, Best Practices in School Psychology (Thomas & Grimes, 1995) and The Handbook of School Psychology . of insanity.American JournalofForensicPsychology, 16,39 88 . Gerard, H. B. (1 983 ). School desegregation: The social science role. American Psychologist, 38, 86 9 87 7. Gilbert v. California, 388 U.S. 263, 87 S. Ct (1910). Abstracts of lectures on the psychology of testimony. American Journal of Psychology, 21, 273– 282 . Stovall v. Denno, 388 U.S. 293 (1967). Tarasoff v. Regents of the University of California,. States Army, 83 7 F.2d 14 28, rch’g en blanc granted, 84 7 F.2d 1362 (9th Cir. 1 988 ). Weiner, I., & Hess, R. (1 987 ). The handbook of forensic psychology. New York: Wiley. Weinreb, L. (1 986 ). Criminal