Jump to content

Childhood nudity

From Wikipedia, the free encyclopedia

Praia do Abricó, Rio de Janeiro, Brazil (2006)

In contemporary societies, the appropriateness of childhood nudity in various social situations is controversial, with many differences in behavior worldwide. Depending upon conceptions of childhood innocence and sexuality in general, societies may regard social nudity before puberty as normal, as acceptable in particular situations such as same-sex groups, or unacceptable.

Until 20,000 years ago, all humans were hunter-gatherers living in close contact with their natural surroundings. In addition to sharing a way of life, they were naked much of the time. In prehistoric pastoral societies in warmer climates adults might be minimally clothed or naked while working, and children might not wear clothes until puberty,[1] a practice that continued in Ancient Egypt.[2]

Until the final decades of the 20th century, the nudity of all small children and boys until puberty was viewed as non-sexual in Western culture. Since the 1980s, there has been a shift in attitudes by those who associate nudity with the threat of child abuse and exploitation, which has been described by some as a moral panic. Other societies continue to maintain the need for openness and freedom for healthy child development, allowing children to play outdoors nude.

Stages of human development

[edit]

A report issued in 2009 on child sexual development in the United States by the National Child Traumatic Stress Network addressed the questions parents have about what to expect as their children grow up. Preschool children have a natural curiosity about their own bodies and the bodies of others, and little modesty in their behaviors. The report recommended that parents learn what is normal in regard to nudity and sexuality at each stage of a child's development and refrain from overreacting to their children's nudity-related behaviors unless there are signs of a problem (e.g. anxiety, aggression, or sexual interactions between children not of the same age or stage of development).[3] The general advice for non-family caregivers is to find ways of setting boundaries without giving the child a sense of shame.[4] Both parents and caregivers need to understand that a child's explorations of their own and others bodies are motivated by curiosity, not adult sexuality.[5]

Early childhood

[edit]

Sexual awareness begins in infancy, and develops along with physical and cognitive abilities. Preschool children have little sense of modesty, and will seek bodily comfort by removing their clothes and touching themselves.[6] They are curious about the difference between boys and girls, and learn mainly by sight and touch; wanting to see and touch the bodies of others their own age. They usually learn the difference between boys and girls, including themselves, by the age of 3 or 4. They have little understanding of the effects of their behavior on others. As their language use grows, they will use words they have heard (either euphemistic or accurate) for body parts and functions.[7] At age four to six they will ask questions about bodily functions, attempt to see other people when they are naked, and explore the bodies of others their own age.[3]

Normal sexual play includes behaviors such as playing doctor, playing house, imitating intercourse clothed, looking at or briefly touching other children's genitals, sexual talk and jokes, sexual games, and masturbation. Normal sexual behavior is exploratory and spontaneous, not accompanied by strong feelings of anger, fear, or anxiety. These behaviors occur occasionally between peers or siblings who are of similar age, size, and level of development. Caregivers must determine when behavior becomes problematic and requires intervention. In some families any sexual behavior, such as masturbation, may be seen as problematic or unacceptable, even though the behavior is generally viewed as normal by professionals.[8]

Late childhood and adolescence

[edit]

Between the age of 7 and 12 children generally develop a sense of privacy.[3] Puberty begins at about age 10, with many bodily changes including growth spurts. There may be social difficulties depending upon individual differences in sexual development of children the same age. Knowledge of these changes depend upon correct information and educational materials being provided. Parents may be uncomfortable providing such information, and their children may turn to inaccurate information and values contained in movies, television, and the internet.[7]

Pre-pubescent children tend to have friends of the same sex. They may participate in sex play that is motivated by curiosity, and does not reflect upon sexual orientation. Parents may respond to such behavior by providing age-appropriate guidance regarding social rules.[7]

Puberty occurs between ages 10 and 17.[7] Although the capacity for logical thinking may be reached by 16, psychosocial maturity, the ability to make decisions under stress or emotions may not occur until after 18, creating a maturity gap.[9] Behaviors between adolescents of the same age are generally considered normal by professionals if it does not involve coercion or purely sexual motivation. Otherwise, appropriateness of sexual behavior depends upon family and cultural traditions regarding physical expression of affection, privacy accorded to children, and openness about sexuality.[10]

Non-Western cultures

[edit]

In tropical parts of Africa, the Americas, Asia, and Oceania everyday nudity began to change only hundreds of years ago during the age of colonization. The remaining Indigenous peoples with little or no contact with outsiders continue to practice traditional dress, including nudity.[11]

In contemporary rural villages of Sub-Saharan Africa, pre-pubescent boys and girls play together nude, and women bare their breasts in the belief that the meaning of naked bodies is not limited to sexuality.[12] In Lagos, Nigeria, some parents continue to allow children to be naked until puberty. There is now an issue with strangers taking photographs, and they worry about pedophiles, but parents want kids to have the same freedom they remember from their own childhood and grow up with a positive body image.[13]

In Islam, the nudity of children is not forbidden until the age of sexual awareness, between five and six. From the age of seven, adult rules of modest dress apply.[14]

During the post-WWII era, Israeli kibbutzim pursued a program to create an ideal society which included social and gender equality. For a time, some kibbutz children were raised communally, boys and girls playing naked outdoors on hot days.[15]

Public bathing for purification as well as cleanliness is part of both Shintoism and Buddhism in Japan. Purification in the bath is not only for the body, but the heart or spirit (kokoro).[16] In the Tokugawa period in Japan (1603–1868), lacking baths in their homes, entire communities frequented public bathhouses where they were unclothed together.[17] With the opening of Japan to European visitors in the Meiji era (1868–1912), mixed public bathing became an issue for leaders concerned with Japan's international reputation.[18] In contemporary Japan, parents and children continue to bathe together through adolescence without regard to gender.[19]

good story

Western cultures

[edit]

History

[edit]

Anthropologist David MacDougall states that in Western cultures: "The sense of shock at seeing children naked seems to be mainly a recent phenomenon."[20] Despite the prudery of the Victorian era in Britain, children being unclothed was accepted as natural and ordinary in many circumstances. Children were free to run about naked in the nursery, and in Britain, children of the royal family were photographed nude in the 1920s and 1930s. Images of nude children appeared in soap ads and fine art.[21]

Children were featured in British nudist magazines during the Interwar period

The British view of childhood as innocent did not extend to America during the same period.[22] In 1891 an American visiting England writes to a travel columnist that he cannot bring his young daughter to the beach without their being surrounded by naked boys. The columnist replies that Englishmen have no problem with their daughters playing with naked boys to the age of ten, but draw a line at fifteen.[23] In England during the Interwar period (1918-1939), a number of schools were established which practiced a utopian educational program that included coeducation and nudity while playing sports or sunbathing. Children were often on the cover of nudist magazines because nude adults could not be displayed on newsstands.[24] Different norms for boys and girls remain into the 20th century, as shown in a 1940s film of an outing for Scouts and Girl Guides in which boys to the age of about ten play nude, while older boys and all girls are dressed.[25]

In a 1927 Swedish documentary about the benefits of swimming, there were three situations depicted. At a lake for family swimming, small children of both sexes were often nude. At a swimming competition for men and boys with no female spectators, suits for boys were optional, and changing was done in the open. At a competition for women, the spectators were mixed and suits were worn.[26]

In the United States, swimming nude was the norm at summer camps, usually but not always segregated by sex. Ernest Thompson Seton describes skinny dipping as one of the first activities of his Woodcraft Indians, a forerunner of the Scout movement, in 1902.[27] A 1937 article on swimming at boy scout summer camps in Washington State includes photographs of boys being naked. Descriptions of special "carnival" days that were coed did not mention whether swimsuits were available for boys. It does state "Both boys and girls enjoy the thrill of swimming in the nude, so on occasion, suits may be discarded for the night plunge." Night swimming was allowed only in camps where this was safe.[28]

In 1909, the New York Times reported that at an elementary school swimming competition, the boys in the 80 pound division (age 8 to 10) competed nude after finding that suits slowed them down.a Boys had been skinny-dipping in open water for generations, which only became a problem when urbanization brought this activity more often into public view. [29] Suits had not been allowed for male-only use of indoor pools from the 1880s, to maintain the cleanliness of water.[30] Through the first half of the 20th century, articles were published in general circulation magazines and newspapers that highlighted the benefits of swimming for health, safety, and wholesome recreation; often with photographs of boys swimming nude.[31][32] In many places in the United States, boys swam nude until the 1970s, when school swimming pools became mixed-gender.[33]

During the era of male nude swimming, it was rarely allowed in girls' classes. In 1947 girls aged 9 to 13 at the Liberty School in Highland Park, Michigan were directed to wear swimsuits by the Superintendent of Schools in response to a protest by mothers to the board of education. Boys in the schools had not worn suits in their classes for years, and girls requested to do the same in order to give them more time in the pool. While following the wishes of parents who believed girls should behave modestly, all the board members disagreed, stating that there was "no moral issue involved".[34][35]

Moral panic

[edit]

A moral panic is "a social movement against an exaggerated or fabricated threat from individuals or groups believed to undermine the safety and security of society". Sexuality is frequently a target of moral panic due to incompatible norms regarding sexual behaviors. In the 1980s and 1990s, a number of charges were brought against daycare providers alleging sexual abuse and satanic rituals, but were rarely sustained; being based upon improper techniques for interviewing children, using leading questions and sometimes coercion to elicit the desired result.[36]

While not denying the existence of pedophilia, public response has often been exaggerated regarding its prevalence and the characterization of the threat as widespread and organized, as in the Pizzagate conspiracy theory.[37] Pedophilia panics in France and the United States were found to be due to sensational media reports and political crusading rather than any increase in molestation incidents, which remain rare.[38] However, the term moral panic should not be used to claim that a social problem is not real, as sometimes occurs.[39]

In a 2009 article for the New York Times "Home" section, Julie Scelfo interviewed parents regarding the nudity of small children at home in situations which might include visitors outside the immediate household. The situations ranged from a three-year-old being naked at a large gathering, to the use of a backyard swim pool becoming an issue when the children of disapproving neighbors participated. While the consensus of reader comments was to allow kids to be kids up to the age of five, there was acknowledgment of the possible discomfort of adults who consider such behavior to be inappropriate. While opponents of child nudity referred to the danger of pedophilia, proponents viewed innocent nudity as beneficial compared to the sexualization of children in toddler beauty pageants with makeup and "sexy" outfits.[40]

Researcher Steven Angelides finds that the social movement to address the issue of child sexual abuse has had the unintended consequence of reinforcing a public perception of pre-pubescent sexuality as nonexistent, which erases the normal sexual development of children.[41]

Nudity in the home

[edit]
Siblings bathing together, Greenbelt MD (1942)

American writer Bonny Rough lived in Amsterdam and the US while raising her children, and learned that Dutch families typically experienced mixed gender family nudity growing up. In the US, children are not likely to have similar experiences; family nudity typically being nonexistent or gender-segregated.[42] A US survey of 500 mental health and child welfare professionals who were predominantly female, white, and middle-aged indicated that siblings of the same gender bathing together was acceptable to the age of 6 to 8, but of mixed gender only to the age of 5 or 6.[43]

Americans avoid talking about the body and sex with their children, in particular not using real or specific names for body parts and functions. Yet giving children correct vocabulary is part of teaching them how to accurately report if they are touched inappropriately. Also, the basic vocabulary is the starting point for a lifetime of sex education, which cannot wait until adolescence to be learned thoroughly. This is made more difficult since most American parents did not learn these things growing up, so they cannot be role models for appropriate behavior. In the Netherlands, sexual education begins at age 4, but in many US communities, early childhood sex ed is thought to be inappropriate.[44]

Parent-child nudity

[edit]

In 1995, Gordon and Schroeder contended that "there is nothing inherently wrong with bathing with children or otherwise appearing naked in front of them", noting that doing so may provide an opportunity for parents to provide important information. They noted that by ages five to six, children begin to develop a sense of modesty, and recommended to parents who desire to be sensitive to their children's wishes that they respect a child's modesty from that age onwards.[45] In a 1995 review of the literature, Paul Okami concluded that there was no reliable evidence linking exposure to parental nudity to any negative effect.[46] Three years later, his team finished an 18-year longitudinal study that showed, if anything, such exposure was associated with slight beneficial effects, particularly for boys.[47] In 1999, psychologist Barbara Bonner recommended against nudity in the home if children exhibit sexual play of a type that is considered problematic.[48] In 2019, psychiatrist Lea Lis recommended that parents allow nudity as a natural part of family life when children are very young, but to respect the modesty that is likely to emerge with puberty.[49]

In Northern European countries, family nudity is normal, which teaches from an early age that nakedness need not be sexual. Bodily modesty is not part of the Finnish identity due to the universal use of the sauna, a historical tradition that has been maintained.[50][51]

Communal nudity

[edit]

In their 1986 study on the effects of social nudity on children, Smith and Sparks concluded that "the viewing of the unclothed body, far from being destructive to the psyche, seems to be either benign or to actually provide positive benefits to the individuals involved".[52]

As recently as 1996 the YMCA maintained a policy of allowing very young children to accompany their parents into the locker room of either gender, which some health care professionals questioned.[53] A contemporary solution has been to provide separate family changing rooms.[54]

The naturist/nudist point of view is that children are "nudists at heart" and that naturism provides the ideal environment for healthy development. It is noted that modern psychology generally agrees that children can benefit from an open environment where the bodies of others their own age of both sexes are not a mystery. However, there is less agreement regarding children and adults being nude. While some doctors have taken the view that some exposure of children to adult nudity (particularly parental nudity) may be healthy, others—notably Benjamin Spock—disagreed. Spock's view was later attributed to the lingering effect of Freudianism on the medical profession.[55]

Peer group nudity

[edit]

Societies have various norms regarding children of similar age being nude together when needed, such as changing clothes or bathing. When very young, this may be in mixed gender groups; with gender segregation beginning at or before puberty. Different norms may apply to girls, on the assumption that they are more modest.[56]

Daycare and schools

[edit]

The normal behavior of very young children may become an issue outside the home. Daycare in Denmark had traditionally been tolerant of nudity and sexuality among preschool children until the beginning of this century, but differences of opinion have arisen with the possibility that not only caregivers but other children being accused of inappropriate behavior or abuse.[57][58]

Communal showers in an East German kindergarten (1987)

In New Zealand, school staff confront different points of view between those that think children are sexual in age appropriate ways that begin before puberty, versus those that think children are asexual until after puberty. In the former view, behavior involving genitals may be seen as normal play; the latter view, any childhood sexuality in seen as a sign of abuse, which may include labeling one child as an abuser.[59]

By the 1990s, communal showers in American schools had become "uncomfortable", not only because students were accustomed to more privacy at home, but because young people became more self-conscious based upon the comparison to mass media images of perfect bodies.[60] The trend for privacy is being extended to public schools, colleges and community facilities replacing "gang showers" and open locker rooms with individual stalls and changing rooms. A 2014 study of schools in England found that 53% of boys and 67.5% of girls did not shower after physical education (PE) classes. Other studies indicate that not showering, while often related to being naked with peers, is also related to lower intensity of physical activity and involvement in sports.[61]

The change in privacy also addresses issues of transgender usage and family use when one parent accompanies children of differing gender.[62]

A shift in attitudes has come to societies historically open to nudity. In the Netherlands children up to age 12 used mixed gender communal showers at school. In the 1980s showering became gender-segregated, but in the 2000s, some shower in a bathing suit.[63] In Denmark, secondary school students are now avoiding showering after gym classes. In interviews, students cited the lack of privacy, fears of being judged by idealized standards, and the possibility of being photographed while naked.[64] Similar results were found in schools in Norway.[65]

Public nudity

[edit]

Some societies, many in Northern Europe, are tolerant of nudity in places designated as appropriate for clothing optional recreation. Young children in the Netherlands often play outdoors or in public wading pools nude.[66] This continues, although parents must now be more vigilant of strangers taking pictures.[67] A school in New Zealand decided in 2008 that it was safer for five-year-old students to change poolside rather than use the crowded changing room at a public aquatic center. After two weeks, the practice was abandoned due to complaints made by other users.[68]

Sex education

[edit]

In a 2018 survey of predominantly white middle-class college students in the United States, only 9.98% of women and 7.04% of men reported seeing real people (either adults or other children) as their first childhood experience of nudity. Many were accidental (walking in on someone) and were more likely to be remembered as negative by women. Only 4.72% of women and 2% of men reported seeing nude images as part of sex education. A majority of both women (83.59%) and men (89.45%) reported that their first image of nudity was in film, video, or other mass media.[69]

In general, the United States remains uniquely puritanical in its moral judgements compared to other Western, developed nations.[70][71] As of 2015, 37 U.S. states required that sex education curricula include lessons on abstinence and 25 required that a "just say no" approach be stressed. Studies show that early and complete sex education does not increase the likelihood of becoming sexually active, but leads to better health outcomes overall.[72]

The health textbooks in Finnish secondary schools emphasize the normalcy of non-sexual nudity in saunas and gyms as well as openness to the appropriate expression of developing sexuality.[73] The Netherlands also has open and comprehensive sex education beginning as early as age 4. In addition to good health outcomes, the program promoted gender equality. Dutch illustrated books for children depict naked bodies when appropriate.[66]

Tous à Poil! (Everybody Gets Naked!), a French picture book for children, was first published in 2011 with the stated purpose of presenting a view of nudity in opposition to media images of the ideal body but instead depicting ordinary people swimming naked in the sea including a teacher and a policeman.[74] Attempts by the Union for a Popular Movement to exclude the book from schools prompted French booksellers and librarians to hold a nude protest in support of the book's viewpoint.[75]

As part of a science program on Norwegian public television (NRK), a series on puberty intended for 8–12-year-olds includes explicit information and images of reproduction, anatomy, and the changes that are normal with the approach of puberty. Rather than diagrams or photos, the videos were shot in a locker room with live nude people of all ages. The presenter, a physician, is relaxed about close examination and touching of relevant body parts, including genitals. While the videos note that the age of consent in Norway is 16, abstinence is not emphasized. In a subsequent series for teens and young adults, real people were recruited to have sex on TV as counterbalance to the unrealistic presentations in advertising and porn.[76] A 2020 episode of a Danish TV show for children presented five nude adults to an audience of 11–13-year-olds with the lesson "normal bodies look like this" to counter social media images of perfect bodies.[77]

A 2009 report issued by the CDC comparing the sexual health of teens in France, Germany, the Netherlands and the United States concluded that if the US implemented comprehensive sex education similar to the three European countries there would be a significant reduction in teen pregnancies, abortions and the rate of sexually transmitted diseases, and save hundreds of millions of dollars.[78]

Depictions

[edit]

Until the late 20th century, nudity of children was shown in the fine arts, photography, advertisements and film to evoke positive associations of innocence in childhood.[21] This was particularly true for boys, the Walt Disney movie Pollyanna in 1960 beginning with a scene of boys skinny-dipping in a river that was consistent at that time with the carefree nature of the story of small-town America in the 1910s. In the 1968 film Robby, based upon Robinson Crusoe, the main characters played by two pre-pubescent boys are naked much of the time.

As noted above, Life magazine routinely published photographs of naked (but modestly posed) boys up to their teens to illustrate articles on American life. In a 1941 article on high schools, a photograph of boys in a gym shower included a caption indicating male communal nudity was symbolic of social equality.[79]

For decades, parents have taken and shared photographs of their infants and young children naked. During the final decades before digital photography, labs processing film photographs might report them to the police as possible evidence of child sexual abuse (CSA), with some charges being filed but few sustained.[80] Sally Mann, whose 1992 book Immediate Family included nude photographs of her three children, all under 10, was criticized by Mary Gordon as sexualizing children regardless of their artistic merit. Mann responded that any sexual connotations came from the viewer, not the images.[81] In her memoir, Mann recounts that during her own childhood in rural Virginia, she had resisted wearing clothes until the age of five.[82]

Facebook policy is to remove all nude images of children from its website based not on indication of abuse, but the possibility of abuse by others.[83] Child pornography laws in the United States (18 U.S. Code § 2251) prohibit the depiction of sexually explicit conduct involving any person under 18, although what constitutes "sexually explicit" may be open to interpretation.[84] In the absence of explicit conduct, the determination of whether a particular image violates the law is subjective, based upon speculation as to the intent of the creator and the response of the viewer.[85]

In recent years, the identification of child sexual abuse material (CSAM) has led to the development of programs that use artificial intelligence to flag images that are then reviewed by humans before further action is taken.[86] The advocacy organization Electronic Frontier Foundation views these programs as a dangerous violation of the integrity of end-to-end encryption which is the basis for the privacy of online communications.[87]

See also

[edit]

Notes

[edit]
a.^ "The athletic prowess of the very small boys in the eighty-pound championship was of less moment to the spectators than the enthusiasm of the youngsters, who discovered in their trial heats that their swimming trunks impeded them, and that they could swim faster nude. Thereafter the rule about trunks went into the discard, and very small boys in a state of nature swam like tadpoles through the many heats necessary for a decision."[88]

Citations

[edit]
  1. ^ Gilligan 2018, p. 16.
  2. ^ Altenmüller 1998.
  3. ^ a b c APA 2009.
  4. ^ Marder 2020.
  5. ^ Rough 2018, p. 90.
  6. ^ Yanek 2020.
  7. ^ a b c d NCSBY 2023.
  8. ^ DePanfilis & Dubowitz 2000, p. 228.
  9. ^ Icenogle et al. 2019.
  10. ^ DePanfilis & Dubowitz 2000, p. 41.
  11. ^ Gilligan 2018, pp. 3–4.
  12. ^ Akas 2017.
  13. ^ Sofola 2022.
  14. ^ Mughniyya n.d.
  15. ^ Fogiel-Bijaoui n.d.
  16. ^ Clark 1994, p. 5.
  17. ^ Kawano 2005, pp. 152–153.
  18. ^ Kawano 2005, pp. 153–163.
  19. ^ Murphy 2016.
  20. ^ MacDougall 2020, p. 214.
  21. ^ a b MacDougall 2020.
  22. ^ Bolin et al. 2021, p. 212, Sexuality through the Life Stages, Part I: Early Childhood Sexuality.
  23. ^ The Sunday Herald 1891.
  24. ^ Pollen 2023.
  25. ^ Amateur home movie film made in the summer of 1945 or later,... | Huntley Film Archives. 1945. Event occurs at 5:21. Retrieved 26 January 2024.
  26. ^ Bad är hälsa (1927). 1927. Retrieved 15 March 2024.
  27. ^ Seton 1951, p. 297.
  28. ^ Torney 1937.
  29. ^ Wiltse 2003.
  30. ^ Gage 1926.
  31. ^ LIFE 1940.
  32. ^ LIFE 1950.
  33. ^ Andreatta 2017.
  34. ^ The News-Palledium 1947.
  35. ^ Iowa City Press Citizen 1947.
  36. ^ Young 2003.
  37. ^ Karger 2022.
  38. ^ Neuilly & Zgoba 2006.
  39. ^ Tiffen 2019.
  40. ^ Scelfo 2009.
  41. ^ Angelides 2019.
  42. ^ Rough 2018, Ch. 1.
  43. ^ Johnson, Huang & Simpson 2009.
  44. ^ Rough 2018, pp. 39–42.
  45. ^ Gordon & Schroeder 1995, p. 16.
  46. ^ Okami 1995, pp. 51–64.
  47. ^ Okami et al. 1998, pp. 361–384.
  48. ^ Bonner 1999, p. 211.
  49. ^ Lis 2019.
  50. ^ Weaver 2010.
  51. ^ Sinkkonen 2013.
  52. ^ Smith & Sparks 1986, p. 183.
  53. ^ McCombs 1996.
  54. ^ Peavey 2008.
  55. ^ Shantz 2017.
  56. ^ Weinberg & Williams 2010.
  57. ^ Leander, Larsen & Munk 2018.
  58. ^ Leander 2022.
  59. ^ Flanagan 2011.
  60. ^ Johnson 1996.
  61. ^ Johansen et al. 2017, p. 42.
  62. ^ Steinbach 2017.
  63. ^ Rough 2018, p. 26.
  64. ^ Frydendal & Thing 2020.
  65. ^ Johansen et al. 2017, pp. 51–55.
  66. ^ a b Rough 2018, pp. 23–24.
  67. ^ Rough 2018, pp. 32–35.
  68. ^ Booker 2008.
  69. ^ Allen et al. 2018.
  70. ^ Uhlmann et al. 2011.
  71. ^ Zafirovski 2007.
  72. ^ Zadrozny 2015.
  73. ^ Honkasalo 2018.
  74. ^ Cherrier 2016.
  75. ^ Melvin 2014.
  76. ^ Steffensen 2017.
  77. ^ Erdbrink & Sorensen 2020.
  78. ^ Feijoo 2009.
  79. ^ LIFE 1941.
  80. ^ Higonnet 1998.
  81. ^ Mann & Gordon 1997.
  82. ^ Mann 2015, p. 17.
  83. ^ Facebook 2023.
  84. ^ United States Code 2023.
  85. ^ Stanley 1991.
  86. ^ NPR 2021.
  87. ^ Mullin 2022.
  88. ^ The New York Times 1909.

References

[edit]

Web citations

[edit]