Posted: August 1st, 2023

Criminal Justice Thesis Paper: Three Strikes

Criminal Justice Thesis Paper: Three Strikes

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The high crime rate in the United States has attracted a lot of attention among criminal justice experts. During the early 1990s, the crime rate in the nation had reached epic proportions (Huigens & Chinea, 2018). The number of violent and serious crimes reached alarming levels and led to a lot of concern among the citizens. To find a solution, there were proposals, enactment and subsequent implementation of the Three Strikes Law. Generally, this is a tough sentencing law that was also meant to create a sentencing approach that allowed the judicial system to limit violent and serious crimes (Males & Macallair, 1999). However, three decades down the line and the efficacy of this legislation remains a subject of debate. Many people question the rationale and the purpose of the law. While advocates for this law believe that it is effective in handling the high crime level, critics identify numerous reasons to oppose this view. Three strike laws have been shown to increase prison overcrowding and they take away judges’ discretion since the only punishment after two offenses are life, they should be eliminated.
Three Strikes Law leads to overcrowding in prisons. The dramatic increase in the number of the incarcerated population is mostly attributed to the Three Strikes Law. Before this legislation was implemented, experts already projected an increase in the prison population (Greenwood et al., 1994). In California for instance, there was a prediction of uncontrolled expansion in the prison population. As a result, there were proposals to increase funding to sustain the high population and to construct more prisons. Ardaiz (2000) indicates that the experts projected over 230,000 interacted people in California by 2000. The authorities were already discussing a proposal to construct 20 new prisons in the state alone. The same proposals were evident elsewhere in the nation.
Although experts’ projections proved higher than the actual population, there was still a significant increase. In 1997, for instance, there were 146,500 people in prison in California with more than 21,000 increases from the original population recorded in 1994 (Ardaiz, 2000). By the end of 1997, there was a further growth of more than 10,500 incarcerated people in the state. Even though the number was less than the 19,000 annual projection, it was still a significant increase (Ardaiz, 2000). While the projections were higher than the actual rate, the Three Strikes Law still increases the prison population. According to Huigens & Chinea (2018), it is not wrong for the government to project a higher number than the actual rate in these contexts since the figures are crucial in policy formulation. If anything, it is essential for the projections to exceed the actual rate to avoid a situation where the high prison population overwhelms the criminal justice system.
Over the past three decades, there has been a significant expansion in the American criminal justice system in terms of facilities and resources due to the Three Strikes Law. Research indicates that there has been more than 400 percent expansion within that period (Jones, 2012). It follows a period of stability before the law came to force. Currently, more than 25 percent of the global prison pupation is housed in the US. There are approximately two million incarcerated people in the nation. According to Jones (2012), the United States registers more than seven million probationers and parolees. It is difficult to detach these increasing figures to the Three Strikes Law when the increase is higher than before the implementation of the legislation.
The overcrowding in prisons has seen the government increase resource investment in this sector. Across the US, state governments spend a collective amount exceeding $43 billion on a matter relating to corrections (Jones, 2012). A study indicates that a nation is likely to incur more than 17 times in terms of cost for having repeat offenders free rather than in prisons (Jones, 2012). In essence, the preference is to incarcerate any repeat offender instead of having them in the streets. It is critical to note that this was the primary purpose of the Three Strikes Law. However, the fact that this legislation has dramatically changed how American governing bodies allocate financial resources means that some key sectors may be deprived of much-needed resources (Sutton, 2013). Sectors like health care, education may be affected by the huge prison population because the government may be forced to divert resources to sustain the huge prison populations at the expense of these key sectors.
The impacts of the Three Strikes Law can be understood by looking at the Californian situation. Before the legislation was enacted, the state had already started assets reallocation strategies to cater for the projected prison population explosion. Jones (2012) reveals indicates that to mandatory sentencing, the taxpayers had to incur $16,300 in correction activities for a single serious crime annually. As of 2008, the state had already imprisoned 250 times criminals under this legislation than any other state with the Three Strikes Law (Jones, 2012). Considering the dramatic population increase in already overpopulated prison facilities, there was a need to release some prisoners to allow for the entry of new offenders in the correctional system. The situation made the effectiveness of the Three Strikes Law in reducing the crime rate in the state questionable because the release of such offenders is detrimental to society.
The assessment of the situation under the Three Strikes Law shows that the effects of incapacitation would be effective if there were fewer chances that the paroled offenders would engage in crimes than the incarcerated under this legislation. It is unrealistic to argue that all the parolees refrain from engaging in crime after being released to the community (Stolzenberg & D’alessio, 1997). While some may be transformed, others go back and re-offend, which leads to the need to put them behind the bars again. By sentencing them to prison again enhances prison population explosions (Jaffe & Sharma, 1998). It is critical to note that the situation may go on and on again, which raises many questions about the effectiveness of the Three Strikes Law in reducing the crime level.
Three Strikes Laws severely impact the roles of the judges since the legislations take the sentencing discretion away from them. Generally, these legislations are different from normal habitual laws. Based on their provisions, life sentencing is mandatory without parole (Janiskee & Erler, 2000). Traditionally, judges were at the forefront of sentencing since they were responsible for considering both the aggravating and mitigating circumstances before imposing a sentence on offenders. According to Couzens and Bigelow (2017), judicial discretion is very crucial for the general well-being of a nation. Across the world, people consider the justice system to be capable of handling all criminal cases and treating people with a high level of humanity in the course of serving justice. It is critical to note that this creates a proper balance within society.
However, the Three Strikes Law creates a rigid formula that renders the roles of judges in the criminal justice system superfluous. According to Sutton (2013), eliminating the likelihood of parole creates a situation where the justice system ignores the fact that there is a possibility to transform even serial offenders. Over the years, there have been a significant number of record convicts who have transformed good works, religions conversions, study and other efforts in the while serving their jail terms (Baldus et al., 2001). Typically, such people deserve a second chance in the community but the Three Strikes Law makes this impossible.
The early critics of the Three Strikes Law when it started in California argued based on the effects of this legislation in the role of judges. Under this legislation, the roles of judges are compromised since, at the third strike, an individual is viewed to be beyond rehabilitation (Ardaiz, 2000). Theories of Criminal Law do not justify this claim. Based on these theories, this argument may prevent the criminal justice system from delivering justified punishments. The Three Strikes Law proposes a severe penalty for offenders on their third strikes and the role of judges in such cases is restricted (Jaffe & Sharma, 1998). They are required to sentence offenders for life even if the area of the strike a combination of three petty felonies. In the United States, there are currently a good number of individuals serving a life sentence for committing less serious felonies.
Three Strikes Law has disproportionate impacts, especially among offenders with ethnic minority backgrounds. There is racial bias within the criminal justice system. For instance, African American men are overrepresented in all the elements of the criminal justice system (Sutton, 2013). They lead in the number of victimizations, arrests, executions, and incarceration. Statistics indicate that approximately 25 percent of young African American men are serving a given criminal sanction (Ardaiz, 2000). The imbalance within the criminal justice system is attributed to the war on drugs. Most African Americans live in poor neighborhoods due to their low socio-economic status. In these locations, people handle drugs in the streets making it easy to identify and arrest the dealers (Males & Macallair, 1999). Most importantly, the authorities find it easy to pursue the war on drugs on the poor locations making it easy for the poor African Americans to interact with the criminal justice system.
Most importantly, studies indicate that drug use among whites and blacks is comparable (Males & Macallair, 1999). As such, it is unrealistic to argue that drug use among blacks is higher than that of the whites. It is generally, expensive for the police to conduct investigations about drug dealings in the suburbs where the whites tend to stay (Males & Macallair, 1999). The primary reason for this is the fact that most drug dealings take place behind closed doors. Considering the situation, more people from the minority groups will serve life sentences since drug-related offenses are usually prior offenses. In these contexts, there will be a significant variation in the number of people under life sentences among the whites and the blacks (Sutton, 2013). Therefore, the Three Strikes Law enhances racial stereotypes.
Three Strikes Law overburdens the court system. At the inception of this legislation, some individuals who would otherwise not proceed to trial had to obtain it (Ardaiz, 2000). In essence, the law leads to many second and third strike cases proceeding to trial. The courts experience high backlogs due to this legislation. The combination of high arrest rates and the Three Strikes Laws increases the burden on defense lawyers, prosecutors, and judges with caseloads that have increased over the past decade (Greenwood et al., 1994). Since Three Strikes Law is associated with a mandatory life sentence, many repeat offenders tend to seek time-consuming and costly trials instead of just submitting plea bargaining. Usually, felonies that are determined through a plea bargain tend to cost approximately $600 to defend. On the other hand, it costs approximately $50,000 to defend a full-blown criminal trial (Stolzenberg & D’alessio, 1997). Because most defendants prefer public defenders, taxpayers tend to cater to the expense.
The variations in state implementation of the Three Strikes Law impacts their criminal justice systems in different ways. Generally, cases that attract the application of this legislation are labor-intensive than other cases of felony (Greenwood et al., 1994). Much of this relates to the fact that this case creates the need to research an offender’s criminal record that is relevant at that time. In several jurisdictions, the plea does not settle the cases. Due to this, most Three Strikes Laws cases proceed to jury trial and subsequently takes longer durations to be concluded. The degree that delays, in conclusion, is subject to the provisions of this law by the specific jurisdiction (Greenwood et al., 1994). Usually, this creates a workload for the professional in the legal system and court backlogs.
Furthermore, Three Strikes Law imposes life sentencing on criminals whose offenses do not warrant such cruel punishments. According to Janiskee and Erler (2000), the primary purpose of the Three Strikes Law is to protect the nation of serious crimes. Most of the proposals of the legislation consist of a wide variety of criminal acts ranging from minor assaults to rape. In the past, prosecutors have opposed the Three Strikes Laws in the United States. Jones (2012) argues that in Washington State, for instance, more than 20 prosecutors persuaded the public to vote against the legislation arguing that it can send offenders to life sentences for crimes that do not reach the threshold for such punishment.
Generally, there have been several instances of cruel sentences of nonviolent petty crimes in various parts of the US due to the Three Strikes Law. Several cases attracted public attention in which many people felt that the punishments were disproportional and cruel. For example, a few hours after Three Strikes Law came into effect in California in 1994, Lester Wallace was sentenced for life having committed tow non-violent burglaries (Sutton, 2013). His third strike was an attempt to steal a car radio before the police arrived. Wallace, the case was interesting because he was still seated on the passenger’s seat when the police arrived. Sutton (2013) argues that some people have argued that he was just an incompetent thief. Even though his case was petty, the Supreme Court indicated that a life sentence for shoplifting was a rational judgment. According to the court, this level of punishment was not unusual and cruel.
Three Strikes Law is associated with a high cost. Research indicates that it costs over $22,000 to keep one prisoner under incarceration per year (Ardaiz, 2000). Considering the huge number of people under incarceration in the United States, the government incurs a lot of financial resources in this sector. Surprisingly, the number is increasing dramatically which means that the cost that the state and the federal governments will incur in this context will increase further (Couzens and Bigelow, 2017). In a broad context, the Three Strikes Law deprives other sectors of the financial resources that would increase the living standards of the citizens. It is reasonable to argue that the government would have had more financial resources to invest in other sectors of the economy.
For a long time, advocates for the Three Strikes Law have tried to justify the financial cost of crime in society. They use various approaches in including Victim Costs and Consequences. Under this strategy, they identify both tangible and intangible costs of various crimes. The resulting conclusions are not unreliable and inaccurate (Ardaiz, 2000). Generally, there is no standard measure for evaluating the cost of crime. For instance, it is difficult to financially quantify the anguish attributed to crime. Therefore, the figures that the advocates for Three Strikes Law release about the cost of crime in society are may be higher than the actual cost. It is only reasonable to consider measurable factors in estimating the cost of crime in society (Huigens & Chinea, 2018). The primary approach in investigating the cost of crime in society is by calculating the amount of money society saves for having a low number of people in prison.
Three Strikes Law is not an effective approach to crime deterrence. According to Ardaiz (2000), when a repeat offender knows about the existence of this legislation and engages in a crime, then this law is not the best approach for deterrence. Generally, there are laws for all forms of crime but the number of people who engage in such acts is on the rising trend. The simple truth is that the law is not an effective way of deterring crime (Helland & Tabarrok, 2007). The Three Strikes Law mainly focuses on incarceration to deter crime in the community. However, incarceration has proved ineffective in matters relating to the rehabilitation of such criminals. It is, therefore, difficult to consider incarceration in matters concerning crime prevention.
Since the Three Strikes Law came into effect in the 1990s, criminologists have conducted several studies to determine its impact on the crime rate. A vigorous analysis indicates that the rate of decline in the crime rate in the states that enacted this law has been the same as the situation before its implementation (Sutton, 2013). There is very little scientific evidence supporting the ability of this legislation to deter crime. According to sociological reports, the possibility of a life sentence is not a deterrent among repeat offenders (Sutton, 2013). Both the previous arrests and convictions do not impact the perception of such offenders about the possibility of being caught. The Three Strikes Law is not an effective deterrent as believed by the law politicians, the law enforcement officers, and the general public.
From the onset, the Three Strikes Law was implemented based on false promises. Notably, the argument on incapacitation having an effect on crime rate is an elementary and strong inherent appeal (Vitiello, 1997). They argued that incarceration makes it physically impossible for the criminals to engage in new crime activities against the public as long as they will be imprisoned. The intuitive appeal of the argument arises from the notion that most felons that continue committing crimes after being released from prison normally are still in their younger years. Therefore, an incarceration of these criminals means that the population involved in committing offenses will actually bring the crime rates down.
Professor Franklin Zimring and Dr. Gordon Hawkins offered some sober observations in their book Incapacitation: Penal Confinement and the Restraint of Crime. They first stated that prior to the implementation of the law, Carlifornia had already started incarceration of felons in large numbers (Vitiello, 1997 (Vitiello, 1997)). The crime rates dropped substantially. Nonetheless, the rate for most crimes such as robbery, homicides and thefts experienced slight declines. The large declines were experienced in burglary and larceny. Additionally, these incarceration rates were higher among adult offenders while the declining crime rates actually occurred among the juvenile offenders. As Zimrin and Hawkins would state, at a minimum, it is prudent for the data on these rates to inspire considerable amounts of caution on the function of additional incarceration as a major explanation as why offenses are decreasing in the Carlifornian state (Vitiello, 1997).
The other challenges that accrued at the time were with the cost-benefit analysis propagated by the proponents of the rule. The analysis followed the basis of identifying the crime rates of offenders and respective costs of the crime prevented, then multiplying them together to get the benefits of offenders’ incarceration. Through the analysis, a comparison of benefits with the projected expenses of incarceration that would occur in the future is done. It is these measurements in preventing crimes and crime costs which are problematic. The estimates related to crime rates are known to be notoriously imprecise. Various studies have exhibited a range in disagreements while trying to measure the number of crimes that can be prevented annually. This demonstrates methodological challenges in trying to grasp meaningful quantification (Vitiello, 1997). For instance, the studies have shown profound estimates or prevented crimes ranging between 3 to 187 crimes annually for each offender. These large disparities only reduce the confidence one will have in any of the findings from the involved studies.
The reasons for the wide array of differences could be attributed to the distinct methodologies used in achieving the outcomes. Considering a study choosing to utilize the self-reporting method in its research, the primary pitfall is substantial concerns on the motive and memory of the respondents. Other times, the studies may choose crime offenders who are at a height of their respective careers and were just very active. For any flaws that occur in the measurements, they become increasingly exaggerated when the numbers are used in projections for a significant number of years. Furthermore, it has been stated that studies that focus on crime rates rather than community impact would easily overstate the benefits accrued from incarceration. This is because they ignore the fact that offenders continuously commit crime in groups and the incarceration of one individual in the group causes a little effect on crime rates. It is easy to replace the leaders in these crime groups or even bring in new offenders and the crimes continue to occur (Vitiello, 1997). Consecutively, incarceration will actually be increasing the number of offenses. For instance, if three thieves commit twenty burglaries annually, when one of them is incarcerated and the other tw remainnative, crime rates are not going to go down. It is the constant methodological flaws in research studies that should have raised the questions on whether the Three Strikes Law was actually going to bring in the benefits it promised.
Three Strikes Law does not value rehabilitation. The crime prevention approaches under this legislation do not focus on the successful reentry of people into society. Instead, people who are convicted of crimes such as rape, child molestation, and murder did not qualify for safety protection efforts (Greenwood et al., 1994). Evidence-based rehabilitation models propose reentry of incarcerated individuals to the community. Under this model, these individuals can change with the right rehabilitation approach (Helland & Tabarrok, 2007). As such, they qualify for a chance to put their lives on track. Prison reform activists have made an effort to change the measures that state laws use to handle violent and serious felonies. Helland and Tabarrok (2007) indicate that they support a situation where the law does not consider the aspect of ‘threats of violence’ from the categories of felonies that are serious subject to the provisions of the state laws. Such proposals may impact several third-strike offenders, especially whose felony convictions took place before the enactment of this legislation. Most of these offenders are medically incapacitated and have gone through self-rehabilitation.
A wave of Three-Strikes Laws that swept across the USA during the Reagan and Bush regimes changed the view on rehabilitation. Such legislations were viewed as “tough on crime” by their supporters who argued that this was the best approach to deal with career criminals. During this period, the media and politicians hyped crimes creating the perceptions that the focus should only be on repeat criminals (Greenwood et al., 1994). In the end, there was a lot of controversy among the legal experts. Some believed that the Three Strikes Law limited the opportunities for the return of offenders top the community. Huigens and Chinea (2018) argue that rehabilitation is generally an integral part of the justice system of the USA. It gives the offenders the chance to get valuable education in the correctional facilities. Through this, they may become productive members of society once they are released.
The understanding of the role of rehabilitation calls for the need to explore the factors that push an individual to engage in crime. The establishment of rehabilitation within the American justice system the resultant factor of crime. From this perspective, crime is a result of an array of social and psychological factors (Huigens and Chinea, 2018). Therefore, prevention of crime must also consider these factors. The primary objective of the correction of offenders is to identify the conditions and eliminate them through intensive rehabilitation. It is critical to note that rehabilitation is individualized to cater to the specific needs of each offender. According to Huigens and Chinea (2018), each individual’s criminal behavior is a result of different circumstances and situations. From this perspective, the focus on deterrence should be on these conditions and the individual rather than the crime. Under the Three Strikes Law, the focus is always on the crime at the expense of the circumstances that contributed to the offense (Greenwood et al., 1994). Such has been the reason why this law has failed in reducing the crime rate in the USA.
Effective rehabilitation requires a combination of work programs and education at the correctional facilities. The effectiveness of rehabilitation programs is measured through the rate at which rehabilitated and released convict engages in a subsequent offense and the level of recidivism (Huigens and Chinea, 2018). Of all the states that enacted the Three Strikes Law in the 1990s, controversy about its effectiveness has been highest in California than in any other state. The criminal justice system in the state focuses on punishment rather than rehabilitation. The effectiveness of this approach remains a subject of intense debate. The recidivism rate in California is 70 percent and the prisons currently face a lot of budget issues (Huigens and Chinea, 2018). The rate of recidivism is dramatically increasing in the state which creates the need to consider rehabilitation. Interestingly, the policymakers have noticed the ineffectiveness of punishment and are beginning to view rehabilitation as a vital constituent of criminal reconstruction.
When rehabilitation programs are properly designed and implemented, there would be no or little incentive to engage in a subsequent offense. In a study involving more 3,000 incarcerated individuals, in Minnesota, only 22 percent of those who took part in the rehabilitation program engaged in subsequent crimes (Couzens and Bigelow, 2017). The rate of rehabilitation among the US prisoners is still low with only 5 percent of this population are under such programs. In another relevant study conducted by the Commission on Safety and Abuse in America’s Prisons, the findings indicate that rehabilitation can reduce recidivism by approximately 50 percent (Couzens and Bigelow, 2017). To reduce the high crime rate in the United States, there is a need to focus on rehabilitation rather than punishment. However, the effectiveness of this approach relies on the relevance of these programs. If programs fail to meet the required level of appropriateness, it may prove a waste of time and resources.
Macro-level impacts of Three Strikes Law point to the negative. According to Sutton (2013), the analysis of this legislation in various states indicates that jurisdiction-level impacts of the ration of crime-to-crime and political conservatism may alter the effectiveness of Three Strikes Law. The implementation of this legislation is widely skewed by the wide variations in the political climate across the states (Sutton, 2013). While some states like California were more inclined to maximize the implementation of this law, the liberal northern states used avoidance strategies. The wide variation in the level of implementation of the Three Strikes Law conforms to this level of geographical pattern. Under the baseline model, even before this law came into force, there were politically conservative states already punitive in contrast to the situation in the politically liberal states (Sutton, 2013). As is stands, the gap between these two categories of counties will still widen. It is therefore difficult to talk about the efficacy of the Three Strikes Law if it is not universally accepted. Instead of having a skewed implementation as it is the case currently, one would opt for a situation where the legislation is eliminated. Other than reducing prison expenses, rehabilitation also helps in reducing the overall crime rate in society.
Advocates of Three Strikes Law argue that this law has been successful since it creates a room for uniform disposition of all criminal cases and helps in identifying repeat criminals. Admittedly, Three Strikes Law has reduced disparities in sentencing by creating a uniform ground for given categories of offenders (Ardaiz, 2000). The legislation provides clear guidelines that judges are required to follow hence an increased uniformity on the disposition of cases. According to Ardaiz (2000), Three Strikes Law focuses on the criminal history of offenders. Most criminals have a record of violent and serious felony convictions. The existence of criminal sanctions has not successfully deterred such people (Ardaiz, 2000). Through this legislation, it may be easy to identify such individuals and convict them. However, the advocates of this law fail to consider its adverse effects on the overall well-being of society. They fail to understand the impact of the Three Strikes Law on the prison population and the overall judicial system (Sutton, 2013). When the courts and prisons are overwhelmed by the high number of incarcerated individuals, society feels the pressure. Ideally, it is costly to sustain the population and it deprives other sectors the much needed financial resources. The law also enhances some social challenges such as racial stereotypes hence it should be eliminated.
In conclusion, the efficacy of the Three Strikes Law remains subject to intensified debate. While its supporters believe that it is effective in crime reduction, studies fail to find clear effects on violent and serious crimes. As indicated above, Three Strikes Law increases prison overcrowding and they take away judges’ discretion since the only punishment after two offenses is life. Also, disproportionate impacts especially among offenders with ethnic minority backgrounds. Across the United States, African Americans are overrepresented in the criminal justice system. Much of this relates to their low socio-economic status which puts them at risk of direct contact with the criminal justice system. Three Strikes Law enhances inequality further. Other arguments against this legislation are the fact that it is not effective in crime deterrence, does not value rehabilitation and it is cruel. Therefore, Three Strikes Law is attributed to higher costs than gains hence should be eliminated.

References
Ardaiz, J. A. (2000). California’s three strikes law: history, expectations, consequences. McGeorge L. Rev., 32, 1.
Baldus, D. C., Woodworth, G., Zuckerman, D., & Weiner, N. A. (2001). The use of peremptory challenges in capital murder trials: A legal and empirical analysis. U. Pa. J. Const. L., 3, 3.
Couzens, J. R., & Bigelow, T. A. (2017). The Amendment of the Three Strikes Sentencing Law.
Greenwood, P. W., Rydell, C. P., Abrahamse, A. F., Caulkins, J. P., Chiesa, J., Model, K. E., & Klein, S. P. (1994). Three strikes and you’re out: Estimated benefits and costs of California’s new mandatory-sentencing law. Santa Monica, CA: Rand.
Helland, E., & Tabarrok, A. (2007). Does three strikes deter? A nonparametric estimation. Journal of human resources, 42(2), 309-330.
Huigens, K., & Chinea, D. (2018). ‘Three Strikes’ Laws and Apprendi’s Irrational, Inequitable Exception for Recidivism.
Jaffe, M. E., & Sharma, K. K. (1998). Malingering uncommon psychiatric symptoms among defendants charged under California’s “Three Strikes and You’re Out” law. Journal of Forensic Science, 43(3), 549-555.
Janiskee, B. P., & Erler, E. J. (2000). Crime, Punishment, and Romero: An Analysis of the Case Against California’s Three Strikes Law. Duq. L. Rev., 39, 43.
Males, M., & Macallair, D. (1999). Striking out: The failure of California’s three strikes and you’re out law. Stan. L. & Pol’y Rev., 11, 65.
Stolzenberg, L., & D’alessio, S. J. (1997). “Three strikes and you’re out”: The impact of California’s new mandatory sentencing law on serious crime rates. Crime & Delinquency, 43(4), 457-469.
Sutton, J. R. (2013). Symbol and Substance: Effects of C alifornia’s Three Strikes Law on Felony Sentencing. Law & Society Review, 47(1), 37-72.
Jones, J., 2012. Assessing The Impact Of “Three Strikes” Laws On Crime Rates And Prison Populations In California And Washington. [online] Inquiries Journal. Available at: [Accessed 20 April 2020].
Vitiello, M. (1997). Three Strikes: Can We Return to Rationality. 87 J. Crim. L. & Criminology 395.

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