Whether with or without the support and comradeship of other feminists, the only authentic center of change is the prostitute herself. . . . [T]he prostitute is the key figure. Without her participation, all discussion of change is condescending scholasticism.
-Kate Millett, The Prostitution Papers, 1976, pp. 19, 31
It is clear, and seems logical, that those who have extricated themselves from prostitution take a positive view of criminalization [of clients], while those who are still exploited in prostitution are critical of the ban. This pattern is reflected in many different reports and is also confirmed by the contacts that the inquiry had with women with experience of prostitution.
-The Ban against the Purchase of Sexual Services. An Evaluation 1999-2008 (the Skarhed Report), 2010
These two passages signal a noteworthy transformation in feminism. Kate Millett, one of the leading theoreticians of second-wave feminism in the 1970s, insisted that policy formation had to put the prostitute herself at center stage. Otherwise, “all discussion is condescending scholasticism.” Not every feminist would have agreed with Millett even at the time – second-wave feminism was divided about prostitution from the very outset – but her insistence represented an important, perhaps dominant, strand of feminist thought.
The remarks of Anna Skarhed in her government-sponsored 2010 report on the effects of Sweden’s “sex purchase ban” – which criminalizes paying for sexual services – ratified the exclusion of working prostitutes from policy influence. The Skarhed Report makes it quite clear why: working prostitutes won’t endorse the ban the government of Sweden meant to vindicate in the 2010 report. Since the report began with its conclusion – nothing needs to be changed about the sex purchase ban – it hardly made sense to accept as authentic the voices of those who dispute the ban. Those who had “extricated” themselves from prostitution supported the ban, and their voices counted. Those still working as prostitutes were dismissed as still “exploited.”
This pattern prevails throughout abolitionist discourse. Thus, Equality Now, in making its case for “end demand” policies, puts survivors front and center.
Combating sex trafficking and commercial sexual exploitation around the world requires the insight and leadership of survivors who have experienced these human rights abuses. Survivors know first-hand the human rights violations inherent in sex trafficking and commercial sexual exploitation, and are of vital importance in informing effective anti-trafficking efforts.
Those who support the legalisation and decriminalisation of prostitution often do so with the intended goal of making prostitution better and safer for those involved. Yet, survivors of sex trafficking have repeatedly stated that legalisation and decriminalisation of the commercial sex industry does just the opposite. A statement signed by 177 verified sex trafficking survivors from Sex Trafficking Survivors United . . . suggests that: “Without the buyers of commercial sex, sex trafficking would not exist. If we start penalising and stigmatising the buyers, we could end sex trafficking in our lifetime.”
When Janet Raymond of the Coalition Against Trafficking in Women (CATW) set out with Donna Hughes to write a report on trafficking and prostitution, she turned to survivor organizations to identify individuals to interview.
When abolitionist advocates – and even scholars – want to exhibit evidence of prostitution’s atrocious effects, they draw from “evidence” collected by survivor organizations or survivor-influenced studies.
Thus, countless articles and web-site pitches rely on essays and books by Evelina Giobbe, Vednita Carter, Susan Kay Hunter, Jody Raphael, Rachel Moran, and Rachel Lloyd among others – figures who are survivors, or who draw their evidence from survivors, or who use survivors in their research designs.
WHO ARE SURVIVORS?
Every year in the United States and elsewhere thousands of women leave prostitution. Whatever their experiences, most fade silently and invisibly into their surrounding environments. A few do not. Because of trauma, disgust, deep dissatisfaction with their prostitution lives, or for other reasons they seek out “rescue” organizations for support. Most of these seekers then pass on into anonymity themselves, leaving behind, perhaps, their recorded experiences sometimes collected into formal or informal studies. But some do more. They self-identify as “survivors” and lend their voices to the organizations they sought out, or join other such organizations, or form their own.
It is their voices that abolitionists valorize as reliable guides to the nature of prostitution. This valorization rests on two pillars, both of which find expression in Janice Raymond’s 2013 book, Not a Choice, Not a Job: Exposing the Myths about Prostitution and the Global Sex Trade. Here is how she approaches the issue.
Two conflicting voices speak for women in prostitution. Both claim the authority of experience. One voice – survivors of prostitution and their supporters – maintain that prostitution is violence.
The second voice emanates from “sex workers” (Janice Raymond’s scare quotes) and their supporters.
Who [then] speaks for women in prostitution – “sex workers” or survivors? . . . It is difficult to distinguish those who identify as sex workers from those who are agents of the sex industry when many “sex workers” shill for the industry.
So, active “sex workers” – or their spokespersons — are not honest interlocutors; they are shills. Choosing between the voices of survivors or the voices fronting for the sex industry should be a no-brainer. However, in case we remained in doubt, Raymond puts it bluntly: “Survivors are the authoritative voices of women in prostitution.”
Abolitionists use a second maneuver to discredit the voices of actively working prostitutes. Such women may tell us that they choose their work and that for them it represents a reasonable trade-off of benefits and burdens, but their words cannot be credited. They are in “denial.” They suffer from false consciousness. Janice Raymond plays up this element as well:
[W]omen in prostitution develop coping techniques, some of which involve minimizing the harm and exploitation they face day after day. Coping can also generate denial or rationalization of one’s own actions, or those of one’s abusers, to save face.
Here are some other versions of this claim.
Graham et al. (1994) have also described the psychological consequences of being in prostitution. The Stockholm syndrome — a psychological strategy for survival in captivity — is useful in explaining the traumatic bonding which occurs between women in prostitution and their pimps/captors. When a person holds life-or-death power over another, small kindnesses are perceived with immense gratitude. In order to survive on a day-to-day basis, it is necessary to deny the extent of harm which pimps and customers are capable of inflicting. Survival of the person in prostitution depends on her ability to predict others’ behavior. So she develops a vigilant attention to the pimp’s needs and may ultimately identify with his view of the world.
Hélène de Rugy:
Prostitutes who come to us [at Amicale du Nid], do sometimes force themselves to believe they are choosing their lifestyle, because accepting they are victims would be psychologically too much for them to take. In the end they confront this reality, though.
Consent to oppression or an apparent “will” to be objectified is a condition of oppression. It is never a state of freedom. Sexual exploitation is oppression, and that means that it will be accepted and even promoted within the oppressed class.
Once the objective conditions of sexual slavery are recognized . . . the violence that victimizes women forced into prostitution cannot go by unnoticed. Consequently, instead of accepting women’s self-acceptance of their slavery, we must question whether those circumstances are tolerable for any human being . . . . [Many women live with violence] while trying not to see or acknowledge it. This denial of reality creates a form of hiding.
“Women . . . were the first colonized group” . . . . When the colonized internalize the values of the colonizer, colonization is complete.
I think denial exists to a very large degree in the minds of most prostitutes or former prostitutes who maintain that they find or found prostitution a reasonably tolerable profession. Denial is easy here; it’s telling the truth that’s difficult.
Sarah Benson . . .
. . . of Ruhama, says that it is only after these women have left prostitution that their consciousness changes. “Dissociation is a very common experience, a coping mechanism, and our experience of women who have moved on from prostitution, our experience of the survivors’ movement, is that the sex trade is harmful for all involved: there are physical and psychological consequences.”
A writer unsympathetic to this false consciousness theme reports a conversation:
When I asked this . . . counselor if she thought her clients who work as erotic dancers thought of themselves as being “objectified,” she replied: “When a person is doing it they don’t see it as being objectified. It’s more about learning how to demean yourself and do it well. Until someone teaches you what it is, you don’t know you’re demeaning yourself.”
Sex workers who don’t come in from the cold and who insist on occupational liberty haven’t learned; survivors have: that’s the view of abolitionists. That is why the voices of survivors are harkened to and the voices of sex workers are not. The Skarhed Report was nakedly open: sex workers in Sweden don’t support the sex purchase ban; survivors do. Only the voices of latter count.
TAKING ARGUMENTS SERIOUSLY – WHAT DOES IT MEAN?
In the title of this essay I asserted that abolitionists don’t take argument seriously. That seems a very harsh thing to claim. Why do I make it? My answer here can’t be as full as it needs to be; I will say more in later essays. But here I wish to provoke readers to see abolitionist maneuvers from a special and revealing angle.
Start by considering the matter of choice. A crucial concept in the prostitution debate and in understanding trafficking is “consent” or “choice.” Recall that in “8 Cities,” the police interviews return again and again to the theme of voluntariness: whether the brothel workers in their cities are there voluntarily or trafficked in; whether women are being forced into prostitution against their will or not. Abolitionists insist the forced/free distinction is bogus when it comes to prostitution. Prostitution is “not a choice,” to use the title of Janice Raymond’s book. How so?
Here are some typical abolitionist riffs on volition.
We declare that prostitution is usually a consequence of women living in economic and affective misery . . . It is linked to the sexualization of young women and girls. It is therefore not a “choice” of work.
The language of “choice” assumes a range of options. More often the decision to enter prostitution is led by poverty, drug or alcohol dependency, or patterns of abusive behavior.
A woman seldom finds herself becoming involved in prostitution as a result of unlimited choices but rather as a consequence of very constrained circumstances.
Until it is understood that prostitution and trafficking can appear voluntary but are not really free choices made from a range of options, it will be difficult to garner adequate support to assist those who wish to escape but have no other economic choices. The conditions that make genuine consent possible are absent from prostitution: physical safety, equal power with customers and real alternatives.
Another of the tactics in the normalization of prostitution is the attempt to divide prostituted women into . . . those who are supposedly ‘free’ and those who are ‘forced’ . . . . ‘free’ of course indicating those women who have supposedly exercised free will and are happy as larks with their lot.
[A] woman’s compliance in prostitution is a response to circumstances beyond her control, and this produces an environment which prohibits even the possibility of true consent. There is a difference between consent and reluctant submission.
These are but a few samples. They are not ripped out of longer, elaborate analyses of volition; rather they are central parts of essentially throwaway comments on choice or consent. I mean by “throwaway” that the comments can’t be taken as serious arguments; they are just rhetorical conceits. Consider these paraphrases.
You can’t consent if you have no viable alternatives. Yes you can. When the doctor tells you that your disease is fatal unless you undergo surgery, you willingly sign a consent form. You give real consent to the surgery.
You don’t truly consent unless you have a range of unlimited choices. If only Harvard and the local community college accept you for admission, your choice of Harvard isn’t “truly consensual” because you didn’t get offers from Yale, Brown, Stanford, and Princeton – is that what we are to say?
You are free only if you are happy as a lark with what you’ve chosen. You take the job at Microsoft for $300,000 a year but you are disappointed that you didn’t get the better job you really wanted at Google. Even worse, your rival got the Google job. You are not happy as a lark. Are you thus a slave of Microsoft (not free)?
If your compliance is a response to circumstances beyond your control, it’s not truly consensual. We always respond to circumstances beyond our control; our choices are never unconstrained. You wanted the domain names “StopDemand” or “EndDemand” for your new abolitionist website, but both were already taken. You settle for “EliminateDemand.” Are we to say this wasn’t a truly consensual settling-for?
Unless you have equal power your agreements are never valid. Tell that to Bank of America when you refuse to pay your credit card. And if your 11-year-old daughter doesn’t do the homework she promised to do in return for a sleep-over at her friend’s, declaring to you that after all her promise wasn’t valid, how do you respond to her? Do you tell her you’re impressed that she’s becoming a great young feminist!
My responses are glib but hardly less so than the initial claims. A lot more needs to be said about choice and I will say it in later essays.
Abolitionists don’t attach their claims about consent and choice to general accounts, however truncated. Having these accounts in hand, we could see what conclusions they generate about ordinary social transactions, arms-length negotiations, business dealings, promise-makings, marriage vows, consumer purchases, and the like. When does yes mean yes in any of these contexts, and when does it not? If abolitionists took argument seriously they would not couch their claims in such transparently incomplete ways.
More importantly, abolitionists wouldn’t be so complacent in the way they valorize survivors’ voices and rely on them. Studies that use survivors as subjects, or that generate subjects through the mediation of survivors, suffer from sampling bias. No one knows the size and characteristics of the prostitute population as a whole in the United States, but we can be pretty confident that survivors aren’t representative of the whole. We can be confident because they are self-selected or selected by others with a particular vision to promote. They found their prostitution experiences sufficiently repellent to prompt them to join organizations dedicated to abolishing prostitution.
Sampling bias is a serious limitation. Is it taken seriously by abolitionists? In Essay 3, I discussed the research work by Raymond and Hughes, “Sex Trafficking of Women in the United States,” that relied on survivor-run organizations to generate subjects for interviews. Raymond and Hughes say nothing about the unrepresentativeness of their sample. Indeed, Raymond thinks her methodology is empirically exemplary:
Researchers who obtain interviews with women through agencies and organizations that provide services to prostitutes . . . conduct the most reliable evidence-based studies.
Now I want to show you what’s wrong with this complacency.
There’s a parallel universe out there that very closely mimics abolitionist tactics. It’s the “woman-protective” antiabortion movement. Antiabortionists still oppose abortion on straightforward moral grounds (abortion kills innocent life), but tactically the movement twenty years ago began shifting its line of attack. It started offering studies showing abortion’s harm not to the fetus aborted but to the woman aborting it. Now the World Wide Web features numerous sites that, like their abolitionist counterparts, supply an amazing litany of “factoids.”
Did you know that:
28% of post-abortive women attempt suicide?
31% experience suicidal feelings?
60% believe their abortions made their lives worse?
94% regret their decisions to abort?
Did you know that:
Did you know this?
Since many post-abortive women use repression as a coping mechanism, there may a long period of denial before a woman seeks psychiatric care. These repressed feelings may cause psychosomatic illnesses or psychiatric and behavioral [problems] in other areas of her life. As a result, some counselors report that unacknowledged post-abortion distress is the causative factor in many of their female patients, even though their patients have come to them seeking therapy for seemingly unrelated problems.
And did you know this?
Most abortions are unwanted or coerced. Many forced.
Women who have had abortions come from all walks of life. But despite their many differences, many were deceived and manipulated or actively blocked – ironically – from the “choice” they wanted. Many were directly or indirectly forced into unwanted abortions. Still others were blackmailed or threatened, sometimes violently. It’s no wonder that a growing number of women see abortion as a tool by which many teens and women of all ages have been abused, abandoned and exploited.
Upon what are these factoids based?
Many are based on David Reardon’s Aborted Women, Silent No More. Reardon surveyed a sample of 252 women who had had abortions. The 252 women were located and contacted through 42 WEBA chapters around the country. WEBA stands for Women Exploited By Abortion, an organization founded in 1982 “to minister to the needs of aborted women.” Reardon is alert to the problem of sample bias, so he compares the WEBA sample along several dimensions with all women who have had abortions. In terms of age, the WEBA sample is a “relatively close match.” The same is true with regard to marital status, family size, race, and previous abortions. Reardon concludes that the WEBA women “are a fair . . . representation of aborting women in general” – with one exception: “WEBA members are women who today regret their abortions . . .” Even so, many WEBA members “were once very much satisfied with their abortion decisions.” They “represent a matured, reflective point of view of their abortion experience.” On average 10 years had elapsed since their abortions. Their “settled, mature view” of their abortions is now negative. “How accurately their answers reflect the long-term reactions of the general population of aborting women must be judged on whether or not WEBA women represent the attitudes of aborting women in general. We maintain that the WEBA is representative of the aborting population as a whole.” Whatever the limitations of the sample, the survey provides valuable information for “drawing general conclusions.”
Feminists don’t subscribe to the factoids listed above (and I’m sure none of the abolitionist do). They view Reardon’s survey, and the many subsequent studies like it showing abortion damages women’s mental health, as “junk science.” They don’t buy Reardon’s claim that his sample is representative or that any results from surveying it supply valuable information. Yet, how is his procedure or complacency about samples different from Janet Raymond’s, who derives her samples from survivor organizations?
The factoids populating antiabortion websites are a lot like those found at abolitionist sites: not well-referenced (when referenced at all), uniformly negative, disquieting if taken a face value, and rooted in “studies” of varying quality. The studies often fall short – sometimes far short – on scientific rigor.
The abortion debate also provides us with another slant on abolitionist arguments. As we saw above, abolitionists consistently downplay voluntariness: prostitution is not a “choice.” Why not? Because various constraining conditions limit prostitutes’ options. However, when it comes to abortion decisions, which are often made in highly constraining conditions, feminists rally around a woman’s right to choose. Moreover, they press to assure that this right is extended to girls younger than 18. They fight parental notification laws (achieving partial victory – the Supreme Court requires any state parental notification law to allow an “out” – an opportunity for a minor to petition a judge for permission to obtain an abortion without telling her parents) and they support the right of minors to acquire and use contraceptive devices without parental involvement. A girl’s youth, limited opportunities, constrained conditions, and lack of power relative to others – none of these seems to de-legitimate her choice to get an abortion or use contraceptives – although, like abolitionists do with respect to prostitution, the “woman-protection” antiabortionists point to these very factors to support broad claims that abortion is generally “coerced,” not a free and informed decision.
There may be ways to make feminist views on abortion and abolitionist views on prostitution cohere. However, on the surface, at least, abolitionists seem to embrace inconsistent approaches to the two issues. This is why abolitionists need to offer much fuller accounts of good methodology and of consent.
This subject deserves more treatment that I can give it here, but I want to signal a problem with any approach that disqualifies a category of testimony. (It should be obvious in the previous paragraphs that my comment about survivors is not meant to call into question their accounts but to call into question their singular authority.)
As we saw above, abolitionists discount the voices of working prostitutes. If prostitutes say they chose to do what they are doing and have no need of “rescue,” abolitionists respond that the prostitutes are in denial. Really, prostitutes hate what they are doing but say otherwise. They can’t face the truth. They may be literally unable to if, through some psychological process like the Stockholm syndrome, they actually adopt the world view of their oppressors. They have to be de-programmed.
Now, we can’t rule out that all or most prostitutes are psychologically incompetent to assess accurately their own situations. However, abolitionists have certainly never presented any empirical evidence that would come close to supporting such a view. They adopt the “in denial” thesis on much flimsier grounds, and it is a particularly dangerous device to use in investigations of fact. It is dangerous because it becomes what cognitive scientists call an “entrapping schema.” A feature of entrapping schemas – a schema is concept, a theory, a way of understanding the world – is their capacity to be immune from refutation.
Suppose you believe in witchcraft and must interrogate and judge someone accused of being a handmaiden of the devil. The evidence against her? The “spectral evidence” supplied by several adolescent girls convulsed and tormented by the accused. The girls could see the devil in the accused; they could see her authoring their distress though no one else could. (Of course, I am alluding to the Salem witch trials in 1692.) What evidence could count in favor of the accused? How can she defend herself? She denies being a witch? Well, wouldn’t a witch resort to such deceit? You make her denial further evidence against her.She has led an unblemished life — doesn’t that stand in her favor? No: wouldn’t the devil choose to possess just such a person the better to accomplish his designs? You ,make her unblemished life count against her.Having come to believe she is a witch, you turn every piece of evidence to your benefit: there is nothing to be said for her that you do not turn against her.
A more contemporary example shows how, once a particular description gets applied to a person or group, evidence putatively against the application becomes evidence for. After the bombing of Pearl Harbor, California – and the nation at large – became alarmed at the presence of a large Japanese population on the West Coast. This alarm was amplified by the well-known “fact” that the Japanese were a devious people.
“Devious,” like “witch,” easily becomes an entrapping schema.
Indeed, the schema for “deviousness” is very flexible in integrating even evidence that potentially contradicts it. Consider, for example, a situation from World War II where the U.S. government was concerned that Japanese-Americans might engage in devious, subversive activity. Earl Warren, who was then governor of California, was testifying before Congress about whether Japanese-Americans constituted a threat to the government: “I take the view that this [lack of subversive activity on their part] is the most ominous sign in our whole situation. It convinces me more than perhaps any other factor that the sabotage we are to get . . . [will be] timed just like Pearl Harbor was timed . . . .” Note here that the “devious” schema is entrapping because it can flexibly interpret even disconfirming evidence as confirmation.
So, the fact that Japanese inhabitants of California were not committing sabotage was proof that they were saboteurs, and that they needed to be rounded up and removed to camps – as they were in one of America’s less glorious moments.
Viewing prostitutes as victims of false consciousness, or as suffering from Stockholm Syndrome, produces the same kind of immunity against recognizing counter-evidence. The abolitionist chain of reasoning goes like this. Is prostitution horrendous? Survivors say it’s horrendous – that’s evidence for. Working prostitutes say it’s not – but they are in denial, unable to say the truth, so their assertions merely testify to how horrendous prostitution really is, that it could damage them so. Their assertions do not count as evidence against but as more evidence for. The “evidence-based” conclusion? Prostitution is horrendous.
This conclusion is reached by treating working prostitutes as cognitively impaired, judgmentally incompetent. They need rescue.
When Anna Skarhed wrote her report defending the Swedish ban of sex purchases, she made it quite clear that prostitutes’ voices didn’t count.
People who are currently being exploited in prostitution claim that the criminalization has intensified the social stigma of selling sex. They describe having chosen to prostitute themselves and do not consider themselves to be unwilling victims of anything. Even if it is not forbidden to sell sex, they feel they are hounded by the police. They feel that they are being treated as incapacitated persons because their actions are tolerated but their wishes and choices are not respected. Moreover, they insist there is a difference between voluntary and forced prostitution.
[t]hose who have left prostitution say that the criminalization of the buyer’s actions has made them stronger. They are able to stop blaming themselves and to feel instead that it is the buyers who are in the wrong and who are responsible for the emotional scars and painful memories they must deal with for the rest of their lives. This is why people who manage to escape prostitution are consistently positive to the [sex purchase] ban. In particular, they point out that the buyers are the ones who entice young people into prostitution, and that there is no voluntary prostitution: the buyer always has the power and the people selling their bodies are always being exploited. However, no one wants to see it that way as long as they are still being exploited.
Survivors support the ban; those “still being exploited” don’t. The former count; the latter don’t. Those “still being exploited” complain the law further stigmatizes them and treats them as “incapacitated persons.” To this complaint, Skarhed rejoinds:
For people who are still being exploited in prostitution, the negative effects of the ban that they complain about must be viewed as positive. The point of the sex purchase ban is to combat prostitution [not to treat working prostitutes as competent persons].
Kate Millett was wrong that excluding the prostitute’s voice renders discussion “condescending scholasticism.” There’s nothing at all “scholastic” about Swedish policy, nor about that of any other country that emulates, or wants to emulate, Sweden. These policies have real effects.
However, Millett was spot-on about the “condescending” part.
 Some context is in order. Millett describes a 1971 New York City feminist conference on prostitution which exploded into “chaos” as the prostitutes in attendance “gathered their still-nebulous rage against their own lives and summarily redirected it toward movement women who appeared to be quite as summarily ‘eliminating’ prostitution, the very means of their livelihood.” Kate Millett, The Prostitution Papers: A Quartet for Female Voice (New York: Ballentine Books, 1976), p. 35.
 Anna Skarhed, Förbud mot köp av sexuell tjänst: En utvärdering 1999–2008 (Prohibiting the purchase of sexual services: An evaluation 1999-2008), Stockhom: Statens Offentliga Utredningar (SOU) 2010: 49, p. 30 (“One starting point of our work has been that the purchase of sexual services is to remain criminalised” [English-language Summary]), p. 48. See also p. 60: “En utgångspunkt för vårt arbete har varit att köp av sexuell tjänst fortfarande ska vara kriminaliserat.”
 Skarhed Report, p. 129.
 “United Nations: Listen to survivors – don’t jeopardize efforts to prevent sex trafficking,” September 2013 press release, http://www.equalitynow.org/take_action/sex_trafficking_action511.
 Lauren Hersh, “Europe Is Finally Starting to Tackle Prostitution in the Right Way,” theguardian.com, Thursday 12 December 2013, http://www.theguardian.com/commentisfree/2013/dec/12/europe-prostitution-sex-trafficking-nordic-model.
 Evelina Giobbe, “An Analysis of Individual, Institutional, and Cultural Pimping,” Michigan Journal of Gender & Law, Vol. 1 (1993), pp. 33-57; Vednita Carter and Evelina Giobbe, “Duet: Prostitution, Racism and Feminist Discourse,” Hastings Women’s Law Journal, Vol. 10 (Winter 1999), pp. 37-57; Susan Kay Hunter, “Prostitution is Cruelty and Abuse to Women and Children,” Michigan Journal Gender & Law, Vol. 1 (1993), pp. 91-104; Jody Raphael and Deborah L. Shapiro, “Sisters Speak Out: The Lives and Needs of Prostituted Women in Chicago” (Chicago: Center for Impact Research, August 2002), p.10; Jody Raphael and Jessica Ashley, “Domestic Sex Trafficking of Chicago Women and Girls,” The Schiller DuCanto & Fleck Family Law Center, DePaul University College of Law, May 2008, p. 3; Jody Raphael and Brenda Myers-Powell, “Interviews with Five Ex-Pimps in Chicago,” The Schiller DuCanto & Fleck Family Law Center, DePaul University College of Law, April 2009; Jody Raphael and Brenda Myers-Powell, “From Victims to Victimizers: Interviews with 25 Ex-Pimps in Chicago,” The Schiller DuCanto & Fleck Family Law Center, DePaul University College of Law, September 2010; Rachel Moran, Paid For: My Journey Through Prostitution (Dublin: Gill & Macmillan, 2013); Rachel Lloyd, Girls Like Us: Fighting for a World Where Girls Are Not for Sale, an Activist Finds Her Calling and Heals Herself (New York: Harper, 2011). Vednita Carter & Evelina Giobbe were associated with WHISPER (Women Hurt in Prostitution Engaged in Revolt), “founded by women who have escaped systems of prostitution to create a forum for us to speak about the realities of our lives” (Sarah Wynter, “Whisper: Women Hurt in Systems of Prostitution Engaged in Revolt,” in Priscilla Alexander and Frédérique Delacoste, eds., Sex Work: Writings By Women in the Sex Industry [San Francisco: Cleis Press, 1987], p.270); Carter currently runs Breaking Free, a “survivor-led” rescue group in Minneapolis. Susan Kay Hunter was associated with a Portland, Oregon organization called the Council on Prostitution Alternatives. Rachel Moran is a leading figure in SPACE International (Survivors of Prostitution-Abuse Calling for Enlightenment); Rachel Lloyd created and runs GEMS (Girls Educational & Mentoring Service), a prostitute “exit” organization.
 Janice G. Raymond, Not a Choice, Not a Job: Exposing the Myths about Prostitution and the Global Sex Trade (Washington, DC: Potomac Books, 2013).
 Janice Raymond, Not a Choice, p. 9.
 Janice Raymond, Not a Choice, p. 11.
 This ploy isn’t restricted to Raymond. Other abolitionists use it too. Kajsa Ekis Ekman’s investigations revealed to her that purported sex worker trade unions aren’t real unions, that professed groups for sex workers are fronts for brothel owners, and that writers supporting sex work take money from nefarious sources and intentionally cover up inconvenient facts. Kajsa Ekis Ekman, Being and Being Bought: Prostitution, Surrogacy, and the Split Self, trans. Suzanne Martin Cheadle (Melbourne: Spinifex Press, 2013), pp. 47-84. See also Meghan Murphy, “Interview: On the Sex Industry, Individualism, Online Feminism, and the Third Wave,” August 2, 2013, http://feministcurrent.com/7800/interview-meghan-murphy-on-the-sex-industry-individualism-online-feminism-and-the-third-wave/ (“‘Sex worker unions’ have been shown, thanks to journalists like Julie Bindel, to be little more than lobby groups for the industry”); Christine Stark, “Girls to Boyz: Sex Radical Women Promoting Pornography and Prostitution,” in Christine Stark and Rebecca Whisnant, eds., Not for Sale: Feminists Resisting Prostitution and Pornography (Melbourne: Spinifex, 2004), p. 279 (sex radicals are “sidling up to tricks and porn users”), p. 280 (those who defend prostitution and pornography resort to “emotion” rather than analysis), and p. 281 (sex radicals and prostitute support groups engage in “duplicity”); D. A. Clarke, “Prostitution for Everyone: Feminism, Globalization, and the ‘Sex’ Industry,” in Stark and Whisnant, Not for Sale, p. 170 (“The language of ‘feminist’ and Left-leaning apologists for prostitution eerily echoes the language of corporate CEO’s and their apologists”); Rachel Moran, Paid For, p. 223 (“The term ‘sex worker’ is a rhetorical weapon” masking an unsavory “agenda”); Catharine A. MacKinnon, “Trafficking, Prostitution, and Inequality,” Harvard Civil Rights-Civil Liberties Law Review, Vol. 46 (Summer 2011), p. 306 (“ the moral distinctions that organize the debate on prostitution [and deployed by academics, sex workers, and sex worker advocates], examined in light of reality, emerge as ideological [i.e., as false distinctions to mislead the oppressed and shore up the system of oppression]”).
 Janice Raymond, Not a Choice, p. 181. See also Janice Raymond, “Prostitution as Violence against Women: NGO Stonewalling in Beijing and elsewhere,” July 20, 1998, http://www.catwinternational.org/Home/Article/137-prostitution-as-violence-against-women-ngo-stonewalling-in-beijing-and-elsewhere (” . . . groups who truly represent prostituted women — groups such as WHISPER and the Council for Prostitution Alternatives in the United States — are composed of many women who are survivors of prostitution, or women currently in prostitution trying to leave”).
 Janice Raymond, Not a Choice, p. 21.
 Melissa Farley, Isin Baral, Merab Kiremire and Ufuk Sezgin, “Prostitution in Five Countries: Violence and Post-Traumatic Stress Disorder,” Feminism & Psychology, Vol.8 (1998), pp. 409. Farley neglects to tell the reader that Graham thinks that all women – at least those who love men – suffer from the Stockholm Syndrome. See Dee L. R. Graham et al., Loving to Survive: Sexual Terror, Men’s Violence, and Women’s Lives (New York: New York University Press, 1994), p. xiv (“We propose that women’s bonding to men, as well as women’s femininity and heterosexuality, are paradoxical responses to men’s violence against women . . . women bond to men in an effort to survive, and this is the source of . . . women’s love of men”). See also Melissa Farley, “Prostitution, Trafficking, and Cultural Amnesia: What We Must Not Know in Order To Keep the Business of Sexual Exploitation Running Smoothly,” Yale Journal of Law and Feminism, Vol. 18 (2006), p. 117.
 Interview, The Local (France), November 27, 2013. http://www.thelocal.fr/20131127/prostitution-is-violent-not-just-a-normal-business-deal. Amicale du Nid is a long-time French organization assisting prostitutes to leave the life.
 Kathleen Barry, The Prostitution of Sexuality (New York: New York University Press, 1995), p. 89.
 Kathleen Barry, Female Sexual Slavery (Englewood Cliffs, NJ: Prentice-Hall, 1979), p. 10.
 Kathleen Barry, Female Sexual Slavery, pp. 165-167.
 Rachel Moran, Paid For, p. 152.
 Kate Holmquist, “The Sex Trade: Safe or Sordid?” Irish Times, May 4, 2013, http://www.irishtimes.com/news/crime-and-law/the-sex-trade-safe-or-sordid-1.1382024. Sarah Benson is CEO of Ruhama, a substantial Dublin-based NGO to help prostitutes change their lives.
 Kari Lerum, “Twelve-Step Feminism Makes Sex Workers Sick: How the State and the Recovery Movement Turn Radical Women into ‘Useless Citizens’,” in Barry M. Dank and Roberto Refinetti, eds., Sex Work & Sex Workers (New Brunswick, NJ: Transaction Publishers, 1999), pp. 22-23.
 All-Party Parliamentary Group on Prostitution and the Global Sex Trade, “Shifting the Burden: Inquiry to Assess the Operation of the Current Legal Settlement on Prostitution in in England and Wales,” March 2014, http://appgprostitution.files.wordpress.com/2014/04/shifting-the-burden.pdf.
 Melissa Farley, “Prostitution Is Sexual Violence,” Psychiatric Times, October 1, 2004, http://www.psychiatrictimes.com/sexual-offenses/prostitution-sexual-violence.
 Rachel Moran, Paid For, p. 226.
 Rachel Moran, Paid For, p. 160.
 Janice G. Raymond and Donna M. Hughes, “Sex Trafficking of Women in the United States: International and Domestic Trends” (Washington, DC: Coalition Against Trafficking in Women, March 2001), p. 28.
 Janice Raymond, Not a Choice, p. xii.
 David C. Reardon, Aborted Women, Silent No More (Westchester, Illinois, 1987), pp. 4, xxii.
 David Reardon, Aborted Women, pp. 7-8. Emphasis added.
 The “woman-protection” antiabortion strategy has born considerable fruit. It has spawned a large number of abortion-restricting bills in state legislatures, and scored a significant victory in Gonzales v. Carhart, 550 U.S. 124 (2007), in which the Supreme Court upheld the federal ban on “partial birth” abortions. In writing for the majority, Justice Anthony Kennedy put into play “protecting women from psychological harm” as a Constitutionally sound justification for regulating or restricting abortion: “While we find no reliable data to measure the phenomenon, it seems unexceptionable to conclude some women come to regret their choice to abort the infant life they once created and sustained. . . . Severe depression and loss of esteem can follow.” Justice Kennedy made no direct use to the voluminous literature on Post Abortion Stress Syndrome that supplies many of the factoids noted in the text above, but this literature had created a climate in which Justice Kennedy could take it as common sense that women having abortions run substantial risks of psychological harm, and that they are likely not to be fully informed about a procedure like “partial birth” abortion, thus rendering their “consent” suspect. See Carhart at 510-511. Some of the literature responding to the antiabortionist “woman-protection” strategy includes: Cynthia Cooper, “Abortion Under Attack,” MS Magazine, August/September 2001, http://www.msmagazine.com/aug01/pas.html; Reva B. Siegel, “The New Politics of Abortion: An Equality Analysis of Woman-Protective Abortion Restrictions,” University of Illinois Law Review, Vol. 2007 (2007), pp. 991-1053; Reva B. Siegel, “The Right’s Reasons: Constitutional Conflict and the Spread of Woman-Protection Antiabortion Argument,” Duke Law Journal, Vol. 57 (April 2008), pp. 1641-1692; Chris Guthrie, “Carhart, Constitutional Rights, and the Psychology of Regret,” Southern California Law Review, Vol. 81 (July 2008), pp. 877-903; Caitlin E. Borgmann, “Judicial Evasion and Disingenuous Legislative Appeals to Science in the Abortion Controversy,” Journal of Law and Policy, Vol. 17 (2008-2009), pp. 15-56; Caroline Mala Corbin, “Abortion Distortions,” Washington and Lee Law Review, Vol. 71 (Spring 2014), pp. 1175-1220; J. Shoshanna Ehrlich, “Turning Women Into Girls: Abortion Regret and the Erosion of Decisional Autonomy,” Women’s Rights Law Reporter, Vol. 35 (Spring/Summer 2014), pp. 329-356. For a recent meta-study supporting the claim that abortion produces significant psychological harm in women, see Priscilla Coleman, “Abortion and Mental Health: Quantitative Synthesis and Analysis of Research Published 1995–2009,” British Journal of Psychiatry, Vol. 199 (August 2011), pp. 180-186. See volume 200 (2012), pp. 74-83, of BJP for responses to Coleman. For an excellent analysis of how feminism’s own psychologizing of trauma laid the groundwork for the “woman-protection” antiabortion strategy, see Jeannie Suk, “The Trajectory of Trauma: Bodies and Minds of the Abortion Discourse,” Columbia Law Review, Vol. 110 (June 2010), pp. 1193-1252.
 Chip Heath & Jonathan Bendor, “When Truth Doesn’t Win in the Marketplace of Ideas: Entrapping Schemas, Gore, and the Internet,” Stanford University, March 10, 2003, http://www.gavinoz.com/issues/i/gore.pdf.
 Skarhed Report, pp. 129-130 (“De personer som utnyttjas i prostitutionen uppger att kriminali-seringen förstärkt det sociala stigma det innebär att sälja sex. De beskriver att de valt att prostituera sig och upplever sig inte vara ofrivilligt utsatta för något. Även om det inte är förbjudet att sälja sex upplever de sig vara jagade av polisen. De upplever sig vara omyndigförklarade i och med att deras handlingar tolereras men deras vilja och val inte respekteras. Vidare menar de att man kan skilja på frivillig och tvingad prostitution.”)
 Skarhed Report, p. 130 (“De som tagit sig ur prostitutionen beskriver att kriminali-seringen av köparnas gärningar har givit dem styrka. De har därmed kunnat sluta att skuldbelägga sig själva och i stället kunnat känna att det är köparna som gör fel och har ansvaret för de själsliga sår och svåra minnen som de tvingas leva med resten av livet. Personer som klarat att ta sig ur prostitution är därför genomgående positiva till förbudet. Särskilt framhåller de att det är köparna som lockar ungdomar in i prostitution och att det inte finns någon frivillig prostitution utan att det alltid handlar om att köparen har makten och att den som säljer sin kropp blir utnyttjad, men att detta är något som man inte vill se eller förstå så länge man utnyttjas”.)
 Skarhed Report, p. 130 (“När det gäller de personer som fortfarande utnyttjas i prostitution måste ovan nämnda negativa effekter av förbudet som de beskriver närmast betraktas som positiva sett utifrån perspektivet att syftet med lagen är att bekämpa prostitutionen.”) The segment in brackets in the text is my paraphrase./a>