How do we kill?

Overcoming the Aversion:

How Can Executioners Kill?

“After all, every murderer when he kills runs the risk of the most dreadful of deaths, whereas those who kill him risk nothing except promotion.” Albert Camus

Murder, by most definitions, is the killing of another human being with malice. It requires planning and forethought. Society warrants two exceptions to murder: soldiers and executioners. Both agents of they state, these individuals must execute the will of society. This reality raises many difficult questions. For example, what social, psychological, and moral issues must these individuals overcome in order to kill? How has society carried out capital punishment over time, and how has it changed? How do we prepare these agents of state killing? What measures do institutions take to shelter those who must perform these killings? What are the impacts of killing another human being, even if legal? Who are the victims of this violence?

Aversion to Killing

Humans have an aversion to killing. We as humans and members of society learn not to kill from a young age. Law and religion teach us not to kill. All faiths regard killing as wrong, and only Islam is explicit in allowing capital punishment. Nearly all legal systems outlaw murder and other forms of killing. Another perspective on this aversion is psychological, as shown by Lt. Col David Grossman.


In the Christian and Judaic Traditions, murder is explicitly outlawed by God in his instructions to Moses (Exodus 20:13 ). Other faiths also have scripture banning killing, such as the Qu’ran’s, “You shall not kill any person - for God has made life sacred - except in the course of justice. If one is killed unjustly, then we give his heir authority to enforce justice. Thus, he shall not exceed the limits in avenging the murder, he will be helped"(17:33).[1] This is not an exhaustive list, but illustrates that religion does speak to the issue. For this reason, the United States accepts moral reasons in granting conscientious objection. However, religion is also used to support capital punishment, especially in the Islamic world.


Legally, murder is illegal the world over. We are taught not to kill from a young age. A major change in the question of killing was the separation of murder into degrees, first, second, etc. This allowed the separation of murders from killings, but still, murder is illegal and harshly punished. Capital punishment is justified through this system, but is contradictory to the basic legal principle that premeditated killing is wrong.


Astonishingly, soldiers have an innate aversion to killing. A landmark study after World War 2 by Brigadier General S.L.A. Marshall, the official historian of the Central Pacific and European Theaters of Operations, showed that less than 25% of soldiers fired their weapons in combat. Captain Pete Kilner of the U.S. Military Academy at West Point noted, “Subsequent historical studies of over one-hundred pre-WW II battles have corroborated Marshall’s observation that most soldiers were unable to overcome their own aversion to killing another person.”[2] According to Lt. Col. David Grossman, humans also have a biological aversion to killing our own species. He postulates that not only must one overcome the social aversion to killing in order to do so, but one must also overcome the mammalian brain. Whether this is a case of nature or nurture, murder is unacceptable.

Regardless of ones one belief, our society does have many strong messages against murder and premeditated killing. However, in all cases, for killing to take place it must be justified on religious, moral, legal, and psychological basis. None of these areas provide clear answers, but the diversity of debate shows the innate contradictions those asked to kill are faced with.

A brief history of the death penalty

The historical record is filled with a litany of death, and capital punishment remains one of the most visible ways people have died throughout history. Famous men and women have been sentenced to death by their peers: Socrates, Jesus Christ, St. Joan of Arc, and King Louis XVI to name but a famous few. Although these examples of executions were for crimes against the state, murder today stands as the prime example of a capital crime and many times death is its punishment.

The state has imposed death as a sentence for centuries. The examples above span the full spectrum of history, from the earliest civilizations of Europe (Socrates), the Roman Empire (Jesus), the middle ages (St. Joan of Arc,), and revolutionary France (King Louis XVI). One of the earliest quoted justifications is Hammurabi’s Code: “an eye for an eye…”[3] Throughout the centuries, a litany of crimes led to the death penalty. Only in the nineteenth century did society start to question the practice of capital punishment, and seek its abolition.[4]

Like the west, China too has long had the death penalty, and developed over two hundred methods of execution.[5] In the late eighth century, under Emperor Kanmu Tenno, Japan adopted only two methods: hanging and decapitation. Although Japan has vacillated between periods of abolition and extreme forms of capital punishment throughout its history, hanging remains the mode of execution in modern Japan. This follows from the “normalization” of capital punishment following the Tokugawa reign. Abolition has not followed, except for a short period in the early 1990s. Most Japanese are surprised to learn that it wasn’t carried out throughout time. Quite the opposite is true; the Japanese increasingly approve of the death penalty.[6]

Meanwhile, in the Americas, the death penalty was introduced by the early English colonists who brought it with them to America. During the seventeenth and eighteenth century, in both England and its colonies, the death penalty was often utilized as punishment for a long inventory of crimes. Today many of these crimes seem trivial as capital crimes: embezzlement, fraud, counterfeiting, prison-breaking, robbery, sodomy, bestiality, and blasphemy to name a few.[7] However, it is important to note that there are several major differences between the death penalty then and now.

The death penalty in early American history was a very public affair. Those executed served as examples in their communities – the executions themselves drew large crowds. Public executions took place until the very beginning of the twentieth century. They lasted entire afternoons with hours of speeches by law enforcement officials, politicians, various ministers, and other speakers. Referring to the nature of public executions compared to private affairs Banner said, “Convicted criminals could more easily have been killed without any ceremony at all.”[8] According to Banner, the ceremony of death served three purposes: it served primarily as deterrence to crime, it reinforced order and the power of the state, and it “dramatized the community’s disapproval of violence.”[9] Most important to this method of public execution was the support and participation by the community as a whole. It is worth noting that the condemned were often tried and executed in the community where they committed the crime and within short duration of time after the crime occurred. The entire community was greatly involved in the process. Banner noted, “Government officials, ministers, ordinary citizens – all came together to make an emphatic statement of condemnation.”[10]

Another aspect of the public execution was that they often included long sermons by ministers; this was another purpose of capital punishment. The ministers saw to it that the condemned sought repentance.[11] Although the state is no longer in the business of saving souls, this was an important part of the process in the first half of America’s history. Finally, death was the criminal’s retribution to society. The act of the criminal was seen as a deviation towards evil and a natural tendency for man. “A failure to punish the crime would spread the criminal’s guilt to the entire community.”[12] The very public affair was the business of the members of society.

There was some effort to see that the punishment matched the crime. The Death Penalty itself was often adjusted to fit the crime. Although death seems final, there were various methods to either prolong the fear of death, ensure a tortuous death, or somehow cause more pain in the post mortem. The least tortuous method of death was instead salvation: a false execution.[13] A false execution is best illustrated with the image of the executioner covering the head of the condemned, placing a rope around their neck, and quickly opening the trap door. All of the show and ceremony served only to instill fear in the condemned, for the trap door was not actually under their feet and they could be carried off and beaten.

Altering the method of hanging, such as using chains rather than hanging with ropes, also raised the level of fear for the condemned.[14] However, most additional insult came after death. The corpses of some executed individuals were displayed in public, adding to the states method of prevention. Some were quartered and displayed throughout the jurisdiction. Others were dissected for research purposes.[15] There was also a fear of being buried alive if the hanging wasn’t sufficient.[16] All these methods, some planned others not, worked in the favor of the state to achieve its purposes of punishment, prevention, and penitence.

The methods of execution changed with the introduction of prisons in the late eighteenth century.[17] Massachusetts, New York, and Pennsylvania lead the way by being the first to establish prisons and abolish the death penalty. Kentucky, Virginia, and New Jersey also partially abolished the death penalty and moved to prisons in the 1790’s. As the wealth of individual states increased they could more easily afford to build prisons. Moving to prisons also came in line with a growing desire to ensure the punishment fit the crime – many began to feel hanging for robbery was too much.[18]

The changing sensibilities of the public were the main cause of change in meting out punishments. Throughout the nineteenth century hangings were slowly moved behind closed doors or at least behind the high walls of prisons. The tenor of the crowds led to the downfall of the public execution. Banner noted in his book, “If the crowd was a mob oblivious to the moral lesson a hanging was supposed to impart, it followed that public executions had ceased to serve their original purposes of deterrence and retribution.”[19]

Japan, fully aware of many practices of the west by the end of the nineteenth century, moved its executions behind prison walls. To this day, the Ministry of Justice maintains an extremely high level of secrecy concerning its executions. In an extreme example, the legal counsel for Nakamichi, executed in March of 1993, referred to a living client for weeks after his execution. The ministry of Justice did not even notify the legal counsel of the executed.[20]

The last public execution in the United States, held in Owensboro, Kentucky in 1936, really highlighted the disparity of views both between proponents and opponents of the death penalty. Banner described the scene: “Hot dog and drink vendors set up near the gallows. Spectators jeered throughout, even while [Rainey] Bethea prayed.”[21] The formerly solemn occasion of public death had become a carnival like spectacle. The purpose of the state was no longer fulfilled. To meet new social norms executions were shrouded from public view and sensibilities. Any deterrence the executions provided turned moot.

As the implementation of the death penalty moved behind closed doors, new methods of execution became popular. With the invention of electricity came many new uses including medical treatment, and ultimately new uses in prison as well. One prison began disciplining prisoners with the use of electrical shock.[22] The first electric execution took place in New York on August 6, 1890. It was bungled and it is believed that the condemned, William Kemmler, suffered greatly through his various electrical shocks. Regardless, many states later adopted the electric chair as the preferred means of execution.

With the question of humane treatment rising, other methods of killing were sought. In 1921 both houses of the Nevada State Legislature passed into law the new method of lethal gas execution. Other states followed in the 1930’s, mostly in the south and west, since they had not adopted electric earlier. However, the question of whether the method was cruel and unusual began to gain more voices as the concern for the condemned increased.[23]

The most recent major event in the history of the Death Penalty in America was when the Supreme Court weighed in on the issue in the 1970’s. The issue was an interpretation of the Eighth and Fourteenth Amendments of the Constitution. Although the term “cruel and unusual” had been adopted from the English, and was introduced into their bill of rights in 1689, the meaning of the term as written in the Constitution was much different from our understanding today. Limited debate over the meaning at the time has left a dearth of understanding. Banner said, “The lack of much early litigation on the subject, combined with the virtual absence of recorded debate over the Eighth Amendment and its antecedents, has left little evidence of exactly what Americans of the late eighteenth century understood by the concept of cruel and unusual punishment.”[24]

However, in late June of 1972 in the Supreme Court case Furman vs. Georgia, the Supreme Court declared the death penalty in violation of the Eighth Amendment and thus unconstitutional.[25] As Banner noted, it was a surprise to all that the court had declared it unconstitutional. However, it came at a time when the Death Penalty was less popular in America, especially northern states. Many foreign countries had abolished the death penalty in their own countries. Justice Goldberg noted this, and decided that the definition of cruel and unusual was relative to society at the time and had indeed changed.[26]

Immediately after the judicial ruling, federal and state legislative branches set out to balance the decision. Within four years of Furman vs. Georgia thirty-five states and the federal government had crafted new laws explicitly allowing death.[27] The debate was on, and soon the Death Penalty would be back. Legislatures took two routes to circumvent the Supreme Court ruling. Some states removed discretion from the process by making death mandatory for certain crimes such as first-degree murder. Other states narrowed discretion of juries. This separated the conviction and sentencing phases of trials and required mitigating circumstances in order to execute. With the rewriting of the codes came a rush of new convictions to death row, and a new hearing at the Supreme Court.

This second key case before the Supreme Court, Gregg vs. Georgia, redefined the argument on the death penalty. The earlier case, Furman vs. Georgia, had focused on procedural problems with capital punishment, and the states had fixed those laws. However, the court sided with the states that had chosen a system that split conviction and sentencing. The Death Penalty was back, but the question of morality was still not addressed. The court only sought to ensure the penalty was meted out fairly and without discrimination.[28] Since January 1 of this year, the state has executed 27 men in various states of the United States. Another 3,455 await their executions on Death Row.

This short history illustrates a number of themes. First, over the last two or three centuries the death penalty has fallen out of favor in much of the world, and certainly all of the developed world except for the United States and Japan. This is the direct result of wealth, which allows for other forms of punishment, reform, and/or retribution to be carried out. In 1989, the UN passed the International Agreement to Abolish the Death Penalty.[29] Second, deaths have moved behind closed doors and away from the communities that once carried them out. This directly relates to the professionalization of the role of executioner and the move from the courthouse lawn to the prison yard. Finally, the methods for execution have become both sanitized and institutionalized. This is a direct result of both changes in the technology and its accompanying need for expertise. The result is a modern execution that is highly secretive, well planned, and diffused among a large team of individuals.

The Executioners

The history of Capital Punishment reflects reluctance for the unpleasant. For a short time, there was a friction between the desires to execute publicly and the necessity to do it well. In all cases, throughout history, someone has had to carry out the will of the state. This job falls to the executioner.

Just as the justice system itself, the role of executioner slowly professionalized over time. In the seventeenth century, the British Colony of Massachusetts hired a professional executioner. He was excused from serving on the night watch because of the demanding nature of the work.[30] Other colonies in the Americas resorted to sentencing criminals not to death, but to full time jobs as executioners.

For most of American history, the responsibilities of execution fell to the locally elected sheriffs. In one example from New York, the Sheriff advertised for someone to undertake the job. As Banner notes, “It was not easy to kill a fellow human being, even when the law required it.”[31]

Bungled executions in the late nineteenth century led to calls for change. Some localities shifted the duty to the state penitentiaries, while others hired out the work to private sector experts.[32] They too did not always get it right, and so new methods came into vogue. The new more technical means of execution, such as the electric chair and gas chamber required a standing, professional executioner.[33] This job often fell to the prison electrician. Some states borrowed more experienced individuals from other states.

The modern execution in the United States falls upon the shoulders of an entire team of professionals. The job is diffused across an entire institution of the state, typically the department of corrections. The responsibility of the death follows a very detailed chain of command, ultimately ending with the Governor of the state in question. As there are 38 states in the United States with the death penalty, there are 38 processes for killing someone. They all share similar attributes, but differ on some details. Based upon my own analysis and that of Osofsky and Osofky’s study in the Journal, Psychiatry.


The governor is the highest legal authority in the state, and has the unique power of clemency. This often means that the governor, and only the governor, has the power to stop an execution after all appeals in the legal system have been exhausted. Alternatively, in many states, the governor must personally sign the death warrant of the inmate in question – one of many ironies in the system.

Interestingly, because of last-minute opportunities for clemency, most death row protocols include assuring an open line of communication between the chamber itself and the governor’s office. Some states such as Oregon have extremely detailed plans for maintaining this link via numerous phone tests and radio backups. The governor is the both the person who ensures the death of an inmate, and is their last chance for life.

In 2000, Governor Ryan of Illinois issued a moratorium on the Death Penalty in his state. He noted the powers of the governor in “Debating the Death Penalty.”

The governor has the constitutional role in our state of acting in the interest of justice and fairness. Our state constitution provides broad power to the governor to issue reprieves, pardons and commutations. Our Supreme Court has reminded inmates petitioning them that the last resort for relief is the governor.”[34]

Director of Corrections

As the head official of the state institution carrying out the execution, the director of corrections (or his equivalent) has a number of important roles. Often, this includes processing the paperwork for the execution to take place. Oftentimes, the signature of this person is also required, in addition to the governor, in order for the execution to be carried out.

Prison Warden

This is one of the primary actors in most executions. The warden is the director of all events taking place. In some states, he has very specific duties, including assembling the lethal drugs and other material. More often than not, the warden is present during the execution. One state even has provisions for the warden to hold the hand of the executed as he dies.[35] Furthermore, the warden leads the team, or the rest of this list, and also prays with the members of the “strap-down” team. Ofosky and Ofosky noted that it is the warden who gives the nod to execute, thus he is the executioner via the institution.

Classifications Officers

These are the administrative clerks of the prison who process the paperwork before and after the actual execution. Although they are not in the actual room with the inmate, they have a responsibility to see to their death. They are also responsible for assisting with appeals paperwork and frequent death row to consult with the inmates. In Louisiana, they are present in the death house on the day of the execution. Ofosky and Ofosky note that some have been invited to eat with the inmates at their last meal for they are “among those closest to the condemned.”[36]

Death Row Guards

These are the man and women who guard and interact with the inmate on death row, before and during the execution. Osofsky and Osofsky note that these are the people who know the inmates better than anyone else. They spend eight hours per day together, and some build relationships with one another. It varies with the inmate.

Death House and Front Gate Personnel
In the case of Louisiana, presented by Osofsky and Osofsky, extra guards are brought from other facilities to assist with additional security needs on execution day. They inspect identification of visitors and escort them to their proper places.

Press Liaison

These are the correctional staff responsible for interacting with the media. Osofsky and Osofsky note that these individuals, like the classification officers above, are often overlooked. They must maintain an image of professionalism that is achieved in killing someone. Osofsky and Osofsky quoted one interviewee as saying that dealing with the national (and international) media is more stressful than the actual execution.

Mental Health Professionals

These professionals, like the guards, also get very close to the condemned. Again, Osofsky and Osofsky quoted an interviewee as noting that although their career is to help people, “there isn’t a damn thing I can do for these guys.”[37] Likewise, the authors also note that this is doubly hard in that an important part of counseling includes getting to know the inmates personally. Some note that they “tune out” and do not hear what their patients are saying. “Especially around the time of an execution, they find that such dissociation can be helpful.[38]

Spiritual Advisors

Harking back to earlier days, when getting the condemned to confess their crime was an important role in executions, today’s prisons also have a cadre of chaplains. Like the guards and counselors, these professionals, by nature of their jobs, have an opportunity to get very close to the inmates. All these individuals have noted the difficulty in losing someone they have gotten to know – and also knowing they play a small part in their death.

Victims Family Escorts

These officers have the duty of escorting the victims family before and during the execution. In Louisiana the victims arrive in the early afternoon and are at the prison until the death that evening. Osofsky and Osofsky note that the victim(s) family “passionately talk about where they were and what they felt years ago when they lost their loved one.”[39] Only two members of the family may actually view the execution in Louisiana.

This is one of thirteen states with provisions for the victims family to witness the execution. They all have various regulations regarding everything from numbers to dress codes. The common argument for allowing the families to witness the executions is to bring “closure.”[40] The correctional officers interviewed by Osofsky and Osofsky note this contradiction, and noted that killing the condemned does not bring their loved one (the victim of the crime) back to life.[41]

Inmates Family Escorts

Like the victim(s) family above, the condemned may also have visitors and they too are accompanied by correctional officers. In Louisiana, the family arrives at 8am on the finally day, spending about ten hours with their loved one. Osofsky and Osofsky note that six to eight visitors usually come, however they are not allowed to actually witness the execution. The two families are kept strictly separated, and the only person from the condemned’s entourage to witness the death in the presence of the victim(s) is their lawyer.


Osofsky and Osofsky didn’t include witnesses in their research, however some states also allow citizens to witness the executions. The State of Arizona allows its citizens to apply to witness a random execution. An interested party needs only to submit a letter stating why they wish to witness the execution, and the state adds their name to a pool of potential witnesses.[42] Other witnesses have included journalists, but not cameras. Having witnesses ties back to the former public executions conducted in front of thousands of fellow citizens. Today, with the exception of only a few people, the execution is a very subtle affair.

Strap down Team

A team of up to six correctional officers straps the inmate to the gurney. In Louisiana, these are the highest-ranking and most esteemed officers. One typically supervises, while each of the others takes responsibility for securing a particular part of the body. Osofsky and Osofsky note that this prevents the team members for taking responsibility or identifying with the entire body; instead, they focus on a particular task.

Their nametags are removed, and they all dress alike in dark prison correctional officer uniforms. The large presence of officers is justified by security needs, however there do not seem to be any reports of inmates struggling and refusing to be strapped to the gurney. Osofsky and Osofsky note that “The institution’s dividing the roles of the strapdown team also aids in the diffusion of responsibility for each officer among the other five members of the unit. The number of people involved and the specifics of the rituals and the roles appear to help the officers view their part as strictly professional and their role as a somewhat minor one in sending someone to death.”[43]

Emergency Medical Technicians

Emergency medical technicians insert IVs into the inmate’s arms. Typically two IVs are inserted, one for a backup. However, because some inmates have damaged veins from drug abuse, the IV must be inserted into the neck or some other vein. In Louisiana, the EMT is also responsible for drawing the medicine from the pharmacy. He or she enters the death house through a back entrance to both stay out of the way and to remain anonymous. Patients there are connected to an EKG machine to monitor the heart rate. Osofsky and Osofsky note the irony in how Medical Technicians swab the arms of the inmates with alcohol before inserting the needle. One EMT noted, “During the Execution, I wanted to jump out and start CPR.”[44]


The executioner is sometimes a regular employee of the department of corrections. Sometimes they are from a separate facility, brought to death row for this job only. Florida hires a private citizen, paying them $150 for the job; State law protects their anonymity.[45] Texas utilizes an “injection team” to administer the three chemical agents. According to the Texas Department of Corrections website, “Anonymity is achieved in the execution process by requiring the injection team members to alternate in rendering each injection and by marking the chemical bottles by number only.”[46] Oklahoma too uses three people for three syringes.[47] Osofsky and Osofsky note the difficulty of this job. The most recent executioner resigned and sought psychological treatment, and of the last four executions, there have been three executioners.

Coroner/Medical Doctor

The Death Penalty Information Center notes that doctors cannot participate in executions, but can certify an inmate’s death. In Texas, the locally elected coroner will pronounce the inmate dead. The local county issues death certificates for the executed. Ironically, this certificate states “homicide” as the cause of death.

Controlling the Environment

As noted above, killing another human being is one of the most difficult things someone can do. This is because of cultural, social, and biological constraints. In order to kill, one must violate these various standards. As a result, it is not then possible to kill someone without suffering some psychological effects. We see this on the battlefield. In January of 2004, it was estimated that one in four soldiers serving in Iraq will suffer psychological consequences. Six hundred soldiers have been evacuated from Iraq for psychiatric reasons. At least 22 soldiers have committed suicide, an extremely high number according to The Observer.[48]

In a paper presented to the The Joint Services Conference on Professional Ethics, Captain Pete Kilner, an Instructor at West Point, notes the difficulty the military has in training people to kill. He notes that not only is war psychologically difficult, but so too is the training to kill. The military, according to this report, uses reflexive training. Shoot, then ask questions is the model. Strangely, he proposes a new model for the justification of killing – making it easier to kill. He proposes a model based on self-defense.[49]

What about the executioners? These people are the ones society is asking to bear this burden of killing. Today institutions employ numerous methods in order to make it more acceptable for those taking part to perform their tasks. Throughout history, inventors have developed methods and machines that distance the executioners from the executed. This has been as fancy as machines with random switching, using one blank round among a dozen, utilizing false switches, levers, and buttons. It is accomplished by diffusing responsibility among one of several individuals. However, some states simply avoid this by hiring an anonymous person to perform the execution and paying them for their time – no follow up, no guilt, and no responsibility for creating another victim.

The methods states employ to protect those carrying out executions are enormous and finely detailed through years of development resulting in highly meticulous plans of execution. However, none of the methods employed address the harder questions: what is the psychological impact of killing? It is evident that killing is no easy task. In order to cope with this, we as a society have artificially creating our environment. Has it been successfully constructed? We create physical environments, intuitional environments, and psychological environments – but is it enough to protect those asked to carry out these deeds? Murder creates victims, but so too does the system established to bring resolve to those victims.





[5] Schmidt, Petra. “Capital Punishment in Japan.” Leiden, Netherlands: Brill. 2002. p. 10.

[6] cfm?SectionID=17&ItemID=6368

[7] Banner, Stuart. “Death Penalty.” Cambridge, Massachusetts: Harvard University Press. 2002. p. 6

[8] Banner, p. 51

[9] Banner, p. 52

[10] Banner, p. 52

[11] Banner, p. 19

[12] Banner, p. 23

[13] Banner, p. 66

[14] Banner, p. 74

[15] Banner, p. 79

[16] Banner, p. 83

[17] Berns, p. 45

[18] Banner, p. 99-100

[19] Banner, p. 154

[20] Schmidt, p. 77

[21] Banner, p. 156

[22] Banner, p. 178

[23] Banner, p. 196-199

[24] Banner, p. 232

[25] Banner, p. 231

[26] Banner, p. 249

[27] Banner, p. 268

[28] Banner, p. 275

[29] cfm?SectionID=17&ItemID=6368

[30] Banner, p. 36

[31] Banner, p. 37

[32] Banner, p. 176.

[33] Banner, p. 194.

[34] Bedau, Hugo Adam and Paul G. Cassel, Eds. “Debating the Death Penalty.” Oxford University Press, 2004.

[35] Osofsky, p. 362.

[36] Osofsky, p. 362.

[37] Osofsky, p. 362.

[38] Osofsky, p. 362.

[39] Osofsky, p. 363.

[40] Hodgkinson, Peter. “Victims: meeting the needs of the families.” Capital Punishment. Cambridge University Press, 2004. p. 353.

[41] Osofsky, p. 363.


[43] Osofsky, p. 363.

[44] Osofsky, p. 363.






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