Is Criminal Profiling a Real Science?

The subject of criminal profiling has caught the public’s imagination in recent times, with references to it appearing in all forms of media. The most well-known example of criminal profiling in the popular media is in the film Silence of the Lambs, based on the Thomas Harris novel of the same name. Several television shows have also been based around the premise of criminal profiling, such as Criminal Mind. It is interesting to note that all of these popular portrayals of profiling are somewhat inaccurate because they suggest that profiling is a magical skill somewhat similar to a cognitive psychic ability. Those who practice criminal profiling have claimed that it is alternatively a science or an art, depending on who you listen to. Even those who confess that it is more an art than a science (Ressler & Shachtman, 1992) still point to supposedly scientific studies to support their claims that it is in fact worth using. Profiling may not lead to the exact individual but it often helps police narrow the focus of their investigation.

WHAT IS CRIMINAL PROFILING?

Criminal profiling is the process of using available information about a crime and crime scene to compose a psychological portrait of the unknown perpetrator of the crime. The information that the criminal profiler uses is often taken from the scene of the crime, and takes into account factors such as the state of the crime scene, what weapons (if any) were used in the crime, and what was done and said to the victim (Canter,1989). According to Canter, other information used in criminal profiling can include the geographic pattern of the crimes, how the offender got to and from the crime scene, and where the offender lives. According to Holmes and Holmes (1996), psychological profiling has three major goals to provide the criminal justice system with the following information: a social and psychological assessment of the offender(s), a psychological evaluation of relevant possessions found with suspected offenders, and consultation with law enforcement officials on the strategies that should be used when interviewing offenders. Not all profiles involve all of these three aspects, with the role of the profiler usually being dictated largely by the needs of the law enforcement officials for whom they are consulting. Also, not all crimes are suitable for profiling. Holmes and Holmes state that profiling is only appropriate in cases in which the unknown offender shows signs of psychopathology or the crime is particularly violent or ritualistic. Rape and arson are also considered by Holmes and Holmes to be good candidates for profiling. A profile will rarely by itself solve a crime or catch a criminal, but is designed to be an aid to the investigating police (Wilson & Soothill, 1996). The profile will rarely be so accurate as to suggest a certain individual as being responsible for the crime, but should point the police in the right direction and help reduce the possible number of subjects. When the police have no leads, a profile might suggest some potentially helpful area that the police might have overlooked.

IS PROFILING SCIENTIFIC?

One of the biggest obstacles standing in the way of acceptance of criminal profiling is that there is very little authoritative material on it, and almost nothing in the way of scientific studies to support the claims of the profilers. Many of the law enforcement agencies around the world are still quite skeptical of the work of criminal profilers. Holmes and Holmes (1996) observe that an offender profile is usually only called in when the police have exhausted all other leads, sometimes including psychics and astrologers. Techniques such as forensic DNA analysis have become essential to modern criminal investigation, possibly because one can point to the strong scientific basis on which they are founded. Even though the experimental evidence is still not overwhelming, studies such as those conducted by Pinizzotto and Finkel (1990) suggest that profiling might have some validity. They base this claim on a case study of selected high profile crimes, but do not give any references or source for the data. The main problem with this claim is that it is purely unreliable. Organizations such as the FBI are reluctant to release figures on the successes and failures of the profiles that they provide. Although figures such as an 80% success rate have been circulated (Ressler & Shachtman, 1992), there has yet to be any data put forward to substantiate this claim. According to Ressler (1988), the accuracy of each profile is looked at after an offender has been apprehended so that the profilers may learn from their errors. The evaluation is not performed in public, and most people have no knowledge of how accurate profiles actually are. This is becoming increasingly important, as more private individuals are commissioning profiles themselves (or requesting that the investigating police do) for cases in which they have an interest. There is also the question as to how accurate a profile actually has to be to be of help to the investigating authorities. Obviously, an incorrect profile has the potential to mislead the investigation, but this may only be a problem if the police place a greater amount of faith in the profile than they do in their own investigative skills. Pinizzotto for example, found that from 192 requests for profiles, only 17% actually were used to help identify the suspect. More positively, 77% of the respondents reported that the profile had helped them to focus their investigation. Overall, if profiles are consistently found to be incorrect in at least some aspects, police will quickly lose faith in their worth.

Criminal profilers are responsible for developing psychological profiles of offenders based on the crime scene. Some investigations have led to identification of suspects. However, there are times when this may not succeed. The field has solicited a lot of controversy due to the tactics utilized. Offender profiling, in all its various guises, is still very much a discipline that is yet to be proved. Unlike much of psychology or criminology, the accuracy of an offender profile may have profound implications. If a profile of an offender is wrong or even slightly inadequate police may be misled, allowing the offender to escape detection for a little while longer—and innocent people may be dead as a result. This is not to say that profiles should be ignored or that police should not use them, but that profiling should be approached with caution.

References:

Canter, D. (1989, January). Offender profiles. Psychologist, 2, 12-16.

Holmes, R. M.,&Holmes, S. T. (1996). Profiling violent crimes: An investigative tool (2nd ed.).

Thousand Oaks, CA: Sage.

Pinizzotto, A. J.,&Finkel, N. J. (1990). Criminal personality profiling:Anoutcome and process

study. Law and Human Behavior, 14, 215-233.

Ressler, R. K., & Shachtman, T. (1992). Whoever fights monsters. New York: Pocket Books.

Wilson, P., & Soothill, K. (1996, January). Psychological profiling: Red, green or amber?

Police Journal, 69, 12-20.

Forensic Psychology and Law Enforcement: Police and Investigative Psychology

      The relationship between law enforcement and psychology has improved over the years. Overall, we have seen an increase in the services provided by psychologists to the police community (Bartol& Bartol, 2004, PP. 120). This is partly because law enforcement agencies have become more professional and their administrators are better educated, and partly because the public has demanded more accountability on the part of police. Forensic Psychologists provide assistance to law enforcement agencies across the country in two different categories: police psychology and investigative psychology (Bartol& Bartol, 2004, PP. 128). Police psychology involves the provision of psychological services to law enforcement while investigative psychology refers to the application of psychological science to assist law enforcement in conducting criminal investigations (Bartol& Bartol, 2004, PP. 131).

Police Psychologists play vital roles in the employment and maintenance of police forces. They are often called upon to do pre-employment psychological screening, where they will assess and evaluate the potential new police officer's personality, psychology, intelligence, and overall fit for the line of work (Ostrov, 1986, PP. 355). In addition to pre-employment evaluations, police psychologists may assist with scheduling, educating officers to deal with stress and anger management and assist police officers in dealings with mentally disabled persons (Ostrov, 1986, PP. 358). Police psychologists also provide services with critical incidents, excessive force issues, shootings, police suicides and psychological issues, fitness-for-duty evaluations, and with special unit evaluations (Ostrov, 1986, PP. 360). Critical incidents are situations involving tragedies and deaths, injuries, and life-threatening situations. This area also includes hostage situations and negotiations, though not all police psychologists are involved directly in hostage negotiations. Police psychologists might also be called upon to provide counseling services for officers as well as their families, which can include family and marital issues, divorce, loss, injury, and stress (Ostrov, 1986, PP. 362).

Investigative psychology is perhaps the newest area of specialization for forensic psychologists. It focuses on identifying features of a crime and likely characteristics of its perpetrator. Investigative psychology includes broader areas, such as psychological autopsies, Geographical profiling and the polygraph (Jamel & Adler, 2005, PP. 143).  Psychological autopsies—more formally called reconstructive psychological evaluations—are performed after a person has died and the cause of the death is uncertain or equivocal. The psychologist conducting the autopsy tries to reconstruct the victim’s behavior and thought processes leading up to the death (Jamel & Adler, 2005, PP. 144). This procedure is often used in cases of apparent but questionable suicide. Psychological autopsies are also used—though less frequently—in civil cases in an effort to determine whether a third party may have contributed to the death. For example, an employer may have failed to respond appropriately to signals of extreme emotional distress or threats of suicide. As yet, there is no established, standard method for conducting a psychological autopsy, and its validity has yet to be demonstrated (Jamel & Adler, 2005, PP. 145).

Geographical profiling analyzes spatial characteristics of a crime along with behavioral characteristics of offenders deduced from the crime scene to yield probabilities of a perpetrator residing in a particular location (Gudjonsson, 2003, PP. 160). Geographical profiling is used primarily to solve serial crimes, in which a pattern of offending occurs over time. It is more likely to yield positive results when combined with criminal profiling, although we must caution that the scientific status of the final remains in question (Gudjonsson, 2003, PP. 162).

Polygraph - Like profiling -is not strictly an investigative technique in the narrow sense because it is used in a wide variety of criminal and civil contexts. In law enforcement, it is used primarily in the selection of candidates for law enforcement positions and much less in criminal investigation (Nelson, 1972, PP. 225). Results from polygraph tests are not admitted into courts to be used against criminal defendants, but they have been allowed in some courts to support a defendant’s contention that he or she did not commit the crime (Nelson, 1972, PP. 225). It appears that the polygraph is also being used more extensively in counterintelligence and by federal agencies than it has been in the past. Like the other techniques, the polygraph has not garnered impressive research results with respect to reliability and validity. Nevertheless, some researchers do support its use in limited situations and when administered by highly trained polygraphers (Nelson, 1972, PP. 225).

Forensic psychology role had the most increase in value and significance in law enforcement in the last two decades in two separate sub-disciplines: police and investigative psychology. The work of the psychologist within the criminal justice system can certainly take many routes depending on the specialism of the particular psychologist. From aiding the police in their investigations, advising in the selection of police officers, fitness-for-duty evaluations, conducting psychological autopsies, Geographical profiling and the polygraph , carrying out research or imparting their own knowledge to future criminal psychologists, the work is varied and challenging.

References:

Bartol, C. & Bartol, A. (2004). Introduction to Forensic Psychology. Thousand Oaks, CA: Sage.

Gudjonsson, G. H. (2003). Psychology brings justice: the science of forensic psychology.

            Criminal Behaviour & Mental Health, 13(3), 159-167. Retrieved from EBSCOhost.

Jamel, J., & Adler, J. R. (2005). Forensic Psychology: Concepts, Debates and Practice.

International Journal of Police Science & Management, 7(2), 143-145. Retrieved from EBSCOhost.

Nelson, O. S. (1972). Review of "Legal Psychology". Journal of Applied Psychology, 16(2),

            225-226. doi:10.1037/h0065287

Ostrov, E. (1986). Police/law enforcement and psycholgy. Behavioral Sciences & the Law, 4(4),

            353-370. doi:10.1002/bsl.2370040402

Forensic Psychology and Its Ethical Practice in Court System

      Kenneth Bianchi and his cousin, Angelo Buono, were convicted of raping and killing ten girls and women during a four-month period in the hills above Los Angeles in 1991 (Bardsley, 1998, PP.17). Bianchi had fled to Washington before he was charged and taken into custody. There, he attempted to plea an insanity defense, claiming he had a multiple-personality disorder and that one of his alter egos had committed the crimes. When a forensic psychologist determined that Bianchi was fabricating his mental illness, Bianchi pled guilty and agreed to testify against his cousin in exchange for avoiding the death penalty in the Los Angeles case. He is now serving a life sentence in Washington – his cousin died in prison (Bardsley, 1998, PP.19). Forensic psychologists have been active participants in the court system for nearly a century, providing both treatment and evaluative services for a number of psycho-legal questions. Despite this long-standing relationship with the court, the issue of appropriate psychological evaluation procedures and their potential impact on the court process needs to relatively get attention (Wells, 1987, PP.490).

      The legal system requires that an individual accused of a crime must be competent to stand trial in order to defend himself/herself. Further, an individual may be competent to stand trial, but may have been suffering from a psychological disorder at the time the crime was committed. This could prevent an individual from forming intent to commit a crime. For all these reasons, a forensic psychologist might indicate psychological evaluations of criminal defendants (Viljoen, 2003, pp. 371). In addition, the forensic psychologist's evaluation and report is an important element in presenting evidence for sentence mitigation. Psychological factors that are part of a defendant's personality, which predict a potential behavior pattern are useful in establishing whether that individual was capable of committing the offenses presented at trial (Viljoen, 2003, pp. 374). In Hamblin v. Mitchell, 335 F.3d 482 (sixth Cir. 2003), the Sixth Circuit Court of Appeals reversed the decision of a lower court because counsel did not thoroughly investigate the defendant's mental history in preparation for the sentencing phase of the trial. Specifically, the court stated that such investigation should include members of the defendant's immediate and extended family, medical history, and family and social history (including physical and mental abuse, domestic violence, exposure to traumatic events and criminal violence) (Viljoen, 2003, pp. 378).

      Forensic psychologists also provide evaluation and consulting services for family court matters that overlap with criminal court. Included are child abuse investigations leading to criminal charges, domestic violence evaluations, assessment and counseling of individuals who violate restraining orders, evaluating the credibility of child witnesses, evaluations of juveniles accused of criminal acts, juvenile pre-sentencing evaluations and juvenile probation evaluations (Slobogin, 2003, PP.278).

      In civil court, forensic psychologists are most often engaged as experts to assess emotional factors related to personal injury proceedings. Forensic psychologists assess specific emotional factors that might result from traumatic injury, such as post-traumatic stress, depression, chronic pain or anxiety (Slobogin, 2003, PP.282). If a head injury is present, forensic psychologists may include neuropsychological assessment to evaluate memory dysfunction, or other types of cognitive impairment, which may coincide with the physical injuries. Forensic psychologists may also be asked to evaluate the long term emotional impact of events, such as the impact on a child of losing his/her mother, or the impact of victimization related to a criminal act (Slobogin, 2003, PP.285).

       The ethical behavior of a forensic psychologist is often a subject of speculation. Two forensic psychologists who are both respected professionals of the same field of expertise may one day find themselves contradicting each other in a legal court. During the course of their practice, forensic psychologists must adhere to higher ethical standards of behavior due to the nature of their profession (Bush, 2006, PP.125). These standards are codified in the American Psychological Association's "Ethical Principles of Psychologists and Code of Conduct." Forensic psychologists must not succumb to pressure from the legal system to arrive at a desired outcome. Rather, they must always remain objective practitioners of psychology. Forensic psychologists must provide services only within their areas of expertise and must develop and maintain their areas of expertise on an ongoing basis. Forensic psychologists are duty-bound to maintain confidentiality within the limits defined by law. In addition, forensic psychologists must inform defendants of the extent to which their information will not be confidential and obtain confidentiality waivers (Bush, 2006, PP.173).

     Forensic psychologists use their understanding of psychological principles to assist the courts and the legal system in making complex decisions related to crime or disputes and human behavior. Forensic psychologists can specialize in the areas of family, civil, or criminal court, acting as expert witnesses and performing tasks such as mental competency evaluations, assess the defendant's state of mind of at the time of the offense and investigating claims of child abuse. The psychologist's opinion often has weight in sentencing recommendations and parole hearings, as well as in treatment options and prognosis.


References:

Bardsley, M. (n.d.). Angelo Buono and Kenneth Bianchi, the Hillside Stranglers — The

Rampage Begins — Crime Library on truTV.com. truTV.com: Not Reality. Actuality.. Retrieved March 20, 2011, from http://www.trutv.com/library/crime

Bush, S. S., Connell, M. A., & Denney, R. L. (2006). Ethical practice in forensic psychology: a

systematic model for decision making. Washington, DC: American Psychological Association.

Slobogin, C. (2003). Pragmatic forensic psychology: A means of "scientizing" expert

testimony from mental health professionals?. Psychology, Public Policy, and Law, 9(3), 275-300. doi:10.1037/1076-8971.9.3-4.275

Viljoen, J. L., Roesch, R., Ogloff, J. P., & Zapf, P. A. (2003). The Role of Canadian

Psychologists in Conducting Fitness and Criminal Responsibility Evaluations. Canadian Psychology/Psychologie canadienne, 44(4), 369-381. doi:10.1037/h0086959

Wells, G. L. (1987). Review of "Behavioral scientists in courts and corrections".

Canadian Journal of Behavioural Science/Revue canadienne des sciences du comportement, 19(4), 489-491. doi:10.1037/h0084789

Forensic Psychology in Corrections: Roles and Ethical Dilemmas

The U.S. prison population has grown dramatically in the past decade.  The prison population within the U.S. has reached to the alarming rate of 2 million offenders behind bars (Morgan & Fitzgerald, 2007). Combined with the disproportionate increase in the number of mentally ill and substance-abusing offenders, there is a huge need for correctional and forensic psychologists in penitentiaries. While forensic psychology has become a highly desired discipline and plays a vital role in correctional institutions, it is also questioned with unique ethical dilemmas and conflicts (Gudjonsson & Haward, 1998).

Forensic psychologists have varied responsibilities within corrections. In the field of forensic treatment, these practitioners are required to provide counseling to inmates and ex-offenders. This may include drug education, sex offender treatment, resolution of family problems, crisis intervention, and assistance with problems that can arise due to incarceration (Arrigo, 2000). Counselors may also be responsible for developing and managing programs in order to reduce recidivism rates (Arrigo, 2000). Forensic psychology counselors also work with juvenile offenders in a variety of professional capacities. Forensic counselors run residential juvenile offender programs that include diagnosis, assessment, and treatment planning. Counselors often have the opportunity to provide therapy to clients as well as their families within their homes or a variety of other community settings (Gudjonsson & Haward, 1998). A correctional psychologist’s primary mission is to assist in offender’s rehabilitation and reintegration. However, the primary role of the correctional psychologist, treatment issues and confidentiality has created consistent ethical issues.

The main role of a correctional psychologist is to focus on the treatment of the individual, in order to create behavior changes. However, this approach is no longer the primary focus because with new laws and regulations, correctional psychologists have to focus primarily on the security of the institution and the community at large (Weinberger & Sreenivasan, 1994). These regulations for correctional psychologists have made dual role conflicts which created an environment that can seriously challenge the relationship between the therapist and the individual inmate. Weinberger and Sreenivasan (1994) described a situation when a short staffed correctional psychologist was asked to assist in a simple head count. This did not seem to create a major ethical dilemma, therefore the psychologist agreed. However, once in the correctional worker role the psychologist was ordered to assist in a contraband search of the prisoners. One could suspect that this dual role could destroy the therapeutic image between the psychologist and his clients, thus leaving the therapist recognized solely as another cop.

Another ethical issue that arises for psychologists engaged in forensic work is the issue of confidentiality. The relationship between practitioner and the client (inmate) in a correctional setting is greatly hindered by the limits to of confidentiality (Fowler & Brodsky, 1978). In a non-correctional practice, psychotherapist-patient privileges prevent psychologists from disclosing confidential communications to any other person. However, in the correctional setting information regarding abuse and violence towards others has to be reported in any situation (Fowler & Brodsky, 1978).

The ethical dilemma of neglect in the treatment of inmates with chronic mental illnesses is the next issue that should be considered. Mental health professionals continually have to intervene with angry and disruptive individuals, whether or not their behavior is the product of a chronic mental illness (Weinberger and Sreenivasan, 1994). As a result, those who are experiencing the chronic mental illnesses that psychology can treat (e.g., schizophrenia, mood disorders, suicide), are being forced to take a back seat to disruptive inmates who the correctional institution wants to bring under control (Weinberger and Sreenivasan, 1994).

Correctional psychology is clearly riddled with unique ethical dilemmas and conflicts. The primary roles of the correctional psychologist, treatment issues and confidentiality have created consistent ethical issues. The committee on ethical guidelines for forensic psychologists formulated guidelines for forensic practice in order to provide a more specific method to monitor professional conduct in a correctional setting. However, these standards have not lightened the majority of ethical problems, because they are vague, difficult to understand, and contradictory to other ethical principles (Weinberger & Sreenivasan, 1994).

References:

Arrigo, B. A. (2000). Introduction to forensic psychology: issues and controversies in crime and justice. San Diego: Academic Press.

Fowler, R. D., & Brodsky, S. L. (1978). Development of a correctional-clinical psychology program. Professional Psychology, 9(3), 440-447. doi:10.1037/0735-7028.9.3.440

Gudjonsson, G. H., & Haward, L. R. (1998). Forensic psychology: a guide to practice. London: Routledge.

Morgan, R. , Beer, A. , & Fitzgerald, K. (2007). Graduate students'
        experiences, interests, and attitudes toward
        correctional/forensic  psychology. Criminal Justice and Behavior V. 34 
        No. 1 (January 2007) P. 96-107, 34(1), 96-107. 

Weinberger, L. E., & Sreenivasan, S. (1994). Ethical and professional conflicts
        in correctional psychology. Professional Psychology: Research and
        Practice, 25(2), 161-167. doi:10.1037/0735-7028.25.2.161

What Is Forensic Psychology, Anyway?

"The story of the subconscious mind

can be told in three words:

there is none." --Hugo Münsterberg

The field of forensic psychology has been growing rapidly in recent years. This applied branch of psychology gained recognition with the huge increase in fictional TV shows such as Criminal Minds and CSI which have misinterpreted mainstream society’s view of this filed.  By following the latest television dramas one might think that the main task of a forensic psychologist is to help the police to catch serial killers or profile sex offenders. Although these popular notions regarding forensic psychology may be true in some areas, they do not represent the wide variety of tasks that a trained forensic psychologist can do. My goal is to introduce you to the real world of forensic psychology. In this blog I will briefly discuss the definition and history of Forensic Psychology. In addition I will explain the details about the role of forensic psychology in the three different branches of the criminal justice system – police, Court and correction- in my upcoming blogs.

According to the American Psychological Association(APA), forensic psychology is the “professional practice by psychologists within the areas of clinical psychology, counselling psychology, neuropsychology, and school psychology, when they are engaged regularly as experts and represent themselves as such, in an activity primarily intended to provide professional psychological expertise to the judicial system”(APA, 2011).

This description considers forensic psychology as a branch of applied psychology. Professor Anne Bartol of Castleton State College defines forensic psychology as both a research endeavor that studies characteristics of human behavior related to the legal system such as eyewitness memory, criminal behavior, and the practice of psychology within the legal system, which covers both criminal and civil law (Bartol, 2005). Clinical Psychologistswith training in forensics can be certified through the American Board of Professional Psychology. There is a Psychiatry and Behavioural Science section of the American Academy of ForensicSciences, which is the most interdisciplinary organization available to forensic psychologists (Heilbrun and Brooks, 2010).

To fully appreciate the field of forensic psychology, it is important to understand the historical facts that shaped the identity of this discipline. Forensic psychology was introduced for the first time over a hundred years ago. In 1873 Wilhelm Wundt founded the first psychology laboratory in Leipzig, Germany. He conducted experiments in areas such as witness testimony and criminal evaluation, which are still being used today.

Hugo Munsterberg was one of the first psychologists that studied under Wilhelm Wundt in Germany before moving to the United States in 1892. He set up a laboratory at Harvard University to do experiments on how psychology could be used in the legal system. His work included research on false confessions, witness memory and hypnosis in court.

In 1895, James McKeen Cattellthe head of the Psychology, Anthropology, and Philosophy departments at Columbia University, conducted some experiments that influenced the psychology of testimony. One of Cattell’s goals was to establish psychology as a legitimate science (Bartol& Bartol, 1999 P426).

In 1908 Munsterberg published a book titled "On the Witness Stand" regarding the subject of applying psychology to legal trials. In 1917 one of Munsterberg’s students named William Marston discovered the correlation between systolic blood pressure and whether someone was lying. This discovery led to the development of the polygraph. In 1923, Marston testified in the case of Frye vs. United States and his testimony set the precedent for the use of expert witnesses in court cases.

After World War II psychologists were fully recognized as credible witnesses. This happened in 1940 with the case of People v. Hawthorne. In this case the courts ruled the extent of an expert witness' knowledgewas more important than whether or not they held a medical degree. In 1962, in the case of Jenkins v. United States forensic, psychology experts gained more credibility, where psychologists served as specialists in a mental illness case. Since that timeforensic psychology has come into its own. In 2001, American Psychological Association identified forensic psychology as a speciality within psychology . (Gudjonsson and Haward, 1998 P22-23).

References

Arrigo, B. A. (2000). Introduction to forensic psychology: issues and controversies in crime and justice. San Diego: Academic Press.

Bartol, A. M., & Bartol, C. R. (1999). History of forensic psychology. In Handbook offorensic psychology, 2, 452-470. New York: John Wiley and Sons.

Gudjonsson, G. H., & Haward, L. R. (1998). Forensic psychology: a guide to practice. London: Routledge.

Heilbrun, K. , & Brooks, S. (2010). Forensic psychology and forensic science: A

             proposed agenda for the next decade. Psychology Public Policy and Law,

            16(3), 219-253.

Public Description of Forensic Psychology.(n.d.). American Psychological

           Association (APA). Retrieved February 10, 2011, from

           http://www.apa.org/ed/graduate/specialize/forensic.aspx

Otto, R. K., & Heilbrun, K. (2002). The practice of forensic psychology: A look

           toward the future in light of the past. American Psychologist, 57(1), 5-18.