Holy Fathers

This article was originally posted on Tikkun Daily Blog.

The global Catholic Church is confronting an extraordinary crisis not faced since the Reformation, which began with sharp criticisms of the Church and ended with a schism out of which emerged the establishment of a separate Protestant Church.

Today, sexual abuse allegations against priests are surging in a startling array of nations: the United States and Canada, New Zealand, Australia, France, Italy, Austria, Germany, The Netherlands, Ireland, Switzerland, Belgium, Bolivia, Mexico, Brazil and Chile. New abuse scandals erupt daily. The John Jay School of Criminal Justice estimates that, in the U.S. alone between 1950 and 2002 hundreds of thousands of children have been sexually abused by Catholic Clergy.

In fact, the Catholic Church has a 2,000 year history of sex abuse. In their acclaimed book, Sex, Priests and Secret Codes (2006), Father Thomas Doyle, with former monks Richard Sipes and Patrick Wall, used its own documents to confirm the Church’s 2,000-year problem with clerical sex abuse.

Why has the Church been plagued by so much pedophilia – predominantly homosexual? And why has a scandal regarding this situation erupted only now?

Why Pedophilia?

As to the first question, the sheer extent of homosexual pedophilic abuse within the Church prompts my speculation that an extremely patriarchal institution, combined with the all-male hierarchy’s repudiation of women as equal partners in service and governance, perhaps engenders a homoerotic internal culture that attracts homosexual men to the priesthood. However, those factors alone cannot explain the predominance of homosexual pedophilia. After all, a high proportion of nuns operating in Catholic all-female environments tend to be lesbians — but not lesbian pedophiles (See Lesbian Nuns: Breaking Silence by Rosemary Curb, LibraryThing).

A therapist who treats abuser priests, Leslie Lothstein, proffers another possible explanation. Lothstein implicates the sexual immaturity of priests, who by entering the seminary often as young as 14, miss a critical passage of maturation — first-time sexual experimentation — that is accessible to their non-seminarian peers. Caught in a bind of stunted sexual growth, such men may be driven emotionally to claim and possess their past unexplored adolescent territory that the rules of a celibate priesthood had placed out of bounds.

My own complementary explanation derives from working with two active priests, two former priests, and several ex-seminarians, who quit their studies partly out of disgust with the sexual abuse to which their teachers subjected them. My work demonstrated, sadly, that sexual abuse at the seminary can simultaneously initiate youngsters into homosexual pedophilia and impart the lesson that Catholic institutions tolerate pedophilia. Moreover, such abuse can also cause a victim to later appropriate his former abuser’s predatory/aggressive behavior as psychological compensation for the shame he had felt during the time he was being abused at the seminary.

Let us take note, however, as we consider these issues, that, yes, homosexual pedophilia predominates behind the Church’s walls. Priests do have greater access to males than to females within Catholicism’s sex-segregated communities — there are no altar girls. Priests take boys, not girls, on retreats and camping trips. And yes, solid evidence invites speculation that the generational reproduction of homosexual pedophilia within the Church is partly attributable to a role-reversal syndrome playing out among officials — from priests to bishops — who themselves had been child victims of abuse. All that being as it may, equally solid documentation exists to show that female children, too, are sometimes the victims of sexual abuse within the Church. In fact girls are one quarter of the victims and they are disproportionately under eight years old.

Why Now?

The second and, I think, more crucial question, is why has this long history of a major church’s institutional practice of pedophilia been exposed only now? Why has silence about an explosive open secret persisted for millennia among a leading church’s Faithful, yet been fully exposed within a single decade? What is happening in the world that is prompting Catholics to expose the criminal behavior of numerous “Godly” and “infallible” custodians of their faith?

1. Feudal relationships under attack by the Reformation and capitalism

For an answer, we must return to Christianity’s last great rupture — the Reformation — which ensued as the economic system known as feudalism began to crumble. Under feudalism, serfs labored on the estates of lords, keeping no more than meager amounts of the food and goods needed for their subsistence and reproduction of the next serf generation. Lords of the Manor were entitled to appropriate almost all of the fruits of their serfs’ labor. Both lords and serfs swore love and fealty to each other, but the one party in power — the lords — determined the content of, and enforced, this commitment.

Medieval Catholicism justified this system, holding that God had decreed the lord/serf arrangement. Not coincidentally, the feudal model was compatible with the interests of the Church itself, which was in effect a feudal lordship that owned vast lands.

The Catholic monk, Martin Luther, counted himself among the many who saw and abhorred the extensive corruption existing within the Church. Particularly offensive were the Church’s sale of religious pardons, called “indulgences,” whereby a sinner could purchase exemption from specific penalties and, thus, gain entry into Heaven. Indulgences amounted to the proverbial last straw of corruption that inspired Martin Luther to nail his writ of protest and demands for reform on the door of the Wittenberg Castle Church. Luther’s example spurred the mobilization of a Protestant movement, which grew in spite of the Pope’s excommunication of Luther and attempt to belittle and suppress his criticisms.

This rise of Protestantism was integral with the emergence of new capitalist formations that would spell the beginning of the end of feudalism. The Protestant Church dismissed the concept that salvation depended on obedience to a Catholic hierarchy. And it disdained the feudal laws of birth on which social position and the near enslavement of serfs were predicated.

Consonant with the needs of an ascendant capitalism and its emerging elite, whose status was based on making money, not on birth, an ideology of personal, individual communion with God arose to replace feudalism’s more cumbersome, hierarchical, and expensive constructs.

Historically, turbulence marks periods of momentous change, and the period under discussion here is no exception. As capitalism pressed its economic reorganization of the production of goods and services in the larger economy, pressure came to bear on the rigidly patriarchal extended families that still populated the feudal estates but would not remain there for much longer. As the lords converted to more profitable forms of production, such as sheepherding, evictions of serfs from the lands their families had farmed for centuries accelerated. Other serfs ran away and migrated to cities in search of employment.

The customs and laws of the past could not hold. Families were falling apart. Pregnant women were left unprotected in suddenly undefined and unproscribed circumstances. Children were abandoned. Faced with various social and economic dislocations, people organized and began to make revolutionary demands — demands that proved frightening to both the new elites and the old church.

2. Feudalism resurrected as a model for the family under capitalism

What happened in France just after the French Revolution illustrates the problem. The most radical and youngest elements among the rebels were demanding state assistance to families, including financial support for all children. The new capitalists strongly opposed such state support for the public since they, the remnants of the aristocracy and the Catholic Church, were the only sectors of society wealthy enough to be taxed to pay the bill.

How, then, to lighten the burden of the commoners’ devastated lives and, thus, hold at bay the threat of more revolution? Ironically, feudalism would provide the solution. The French historian, Jacques Donzelot, documents the invention of the “nuclear” household: how a feudalism-inspired model for the organization of household labor and family relationships was facilitated and reinforced.

In the world of serfdom, the father was the autocratic head of the family, who controlled the lives of his wife, his children and his children’s families. The eldest son was second in command, heir to the father’s rigidly patriarchal role. Replication of this model in the world of nascent capitalism elevated the importance of every married man. It conferred upon an ex-serf the role of feudal lord, a wielder of absolute power over his own home — his castle — wife and children. Women enjoyed the “protection,” in pregnancy and child rearing, of a wage-earning male dictator.

The French nation born of the 1789 revolution reinforced “nuclear” families by giving employment and benefits exclusively to men with dependent wives and children. For eligible families, that state support spelled survival — but survival at a price. The new nuclear model reinforced lines of dominance and subordination, teaching children and women alike absolute obedience to a male paternal authority. Birth control in the 17- and early 1800s included abandoning or killing children one did not want. See The Kindness of Strangers: The Abandonment of Children in Western Europe from Late Antiquity to the Renaissance: By John Boswell. The children who survived learned absolute obedience, as well as many other strategies for pleasing their parents.

In sum, power elites forged, out of feudal concepts of domination, submission, authority and obedience, instruments of social control that have served them well to this day in sustaining their elite power and wealth. Largely ignoring people’s cries for help from the state, they shifted onto the nuclear family the cost of raising future generations. Men were disciplined to work until their last breath to support their wives and children. Women were disciplined to maintain homes and raise future obedient employees. (Child-rearing guides developed by religious right-wingers still emphasize absolute obedience; they also affirm women’s subordinate positions within churches: see Spare The Child: The Religious Roots of Punishment; and Does The Catholic Church Hate Women). Interestingly, at its inception the U.S. defined itself as a nation opposed to feudalism, yet it has continued the feudal organization of domestic and emotional labor in the household.

3. How household feudalism is breaking down today

How does all of this relate to the contemporary scandals that are rocking the Catholic Church? The “traditional” family idealized by the religious right and the Catholic Church is feudal in its economic organization. Notwithstanding the housekeeping aids found in most homes, housework is often organized along feudal lines. The wife, like the serf, provides use-value goods like cooked foods, order, cleanliness, and use-value services like food shopping, laundering, child care, low-tech nursing care, management of both children’s and adults’ social lives, elder care, etc. And like the serf, she holds back a portion of her goods and services for her personal use and sustenance. She cooks for herself, her husband and family; she makes the whole bed, including her husband’s side; in many and probably most homes, she cleans everyone’s dishes, etc.

Her labor was, and is today, not considered work worthy of acknowledgment. Rather, it is often viewed as an aspect of her biological makeup and destiny by the Christian, Jewish and Muslim religions, according to each of their Gods’ law. Not only is she not regarded as a wage laborer, she is not seen as a laborer at all, but rather as a person whose DNA compels her to produce use-values consumed in the household. Like her medieval counterpart, she swears love and fidelity to her husband. See Class Struggle on the Homefront: Work, Conflict, and Exploitation .Until recently, the terms of this oath were subject to enforcement by her husband without recourse. But even though ongoing struggles for women’s rights have won passage of laws against abuse in the home, domestic violence is still a leading cause of death for women aged 15-44. Women are often killed after leaving a relationship with a spouse or lover who felt entitled to enforce his terms on her departure.

Children have also been accorded some rights, owing again to feminist activism. However, murdered children are still overwhelmingly the victims of their own families in their own homes (see here and here). Certain prevalent circumstances of the past appeared to rationalize the existence of household feudalism: a family wage for men; unreliable birth control methods; unavailable legal abortion, and the widespread belief in biologically determined sex roles. Let’s consider these factors:

  • The family wage paid to North American white men between 1820 and 1970 enabled the recipients to support a wife whose full time job was cleaning, cooking and providing emotional service to the male head-of-household and the couple’s children. An ideological rationale for that arrangement was the belief that biology is a God-decreed destiny: Women must work at home providing use value services to husbands and children. Women in such feudal households are subordinate to the authority of a male-in-chief. However, this patriarchal, feudal family structure, so enthusiastically celebrated by the Catholic Church, is now eroding, in large part because men’s real wages, i.e. what they can actually buy, have been flat since 1970. Women must work outside of the home for the survival of their families.
  • Birth control is now widely available.
  • Abortion, though often difficult to obtain, is accessible nonetheless.
  • Gender ideology is changing, which means economic conditions supportive of the feudal marriage paradigm are no longer guaranteed. The three quarters of US women who now hold outside jobs are less likely to accept doing all the domestic and emotional labor after a long day’s work in the marketplace. Catholicism’s gender ideology no longer makes sense in modern family life, as evidenced by the faithfuls’ overwhelming disregard for their Church’s prohibition against birth control. More and more people choose not to marry, even when they bear children. A majority of marriages end in separation or divorce, usually initiated by overworked women. Meanwhile, the unquestioned authority of men is eroding along with the feudal family structure. See again Class Struggle on the Home Front . Yet The Catholic Church still bans divorce.

4. A mass movement of Catholics once again challenges the Church’s support of a feudal ideology

The Reformation challenged Catholic Church authority, in part, because its ideology was a class-based justification of feudal exploitation. Today, Catholic Church authority can reasonably be taken to task for being an ideology that justifies the exploitation of women in the household. Today, the feudal “nuclear” family is under scrutiny in the U.S., Europe, New Zealand, Australia, and among educated people in South America — where gender roles are transforming. Those are the places where Catholics are breaking the silence and speaking out about sexual abuse committed by Church fathers.

Just as in the Reformation the feudal economic structure of society at large was breaking down, opening the way for a corrupt religious institution to be exposed and fought, today feudalism’s gradual breakdown within the family is proceeding parallel to a sharp decline in tolerance for the perpetration of sexual abuse by priests and other Catholic clergy.

  • Feudal lords were privileged to demand sex from their serfs, while fathers of the feudal “nuclear” family have had the privilege of committing incest with their children.
  • Although incest among biological fathers has never been legally sanctioned, it has long existed as a devastating secret shame until being exposed by the women’s movement. Similarly, “incestuous” abuse by the Church’s Holy Fathers was an open secret that left its victims ashamed and devastated. Now, Catholic clergy, like other fathers, are increasingly seen as men who must be held accountable to the laws of the land and the laws of their professed morality.
  • Just as during the Reformation, a mass movement arose to expose the corruption of a Church that hid its own criminal sin, in our own time a mass movement of Catholics is again forming to demand transparency, change and punishment of sex crimes.

The Church’s efforts to respond

The Catholic Church’s rigid controls are breaking down. Some priests are demanding the right to marry. Women are demanding the right to be priests. A whopping 59,000 nuns defied their bishops’ orders and supported the Obama health Care plan.

Pope Benedict the XVI, like his predecessor, Pope John Paul, had insisted on his “infallible” authority to use his personal discretion in handling internal Church matters, despite the protection that approach has extended to sex offenders in Church officialdom at the expense of children. In one reported instance, Benedict and John Paul explicitly praised a French Bishop for accepting imprisonment rather than handing over a French pedophile priest to legal authorities: Memo From Vatican City – In Abuse Crisis, a Church Is Pitted ... Benedict and the Vatican hierarchy tried to silence critics by reasserting the absolute authority of the Church hierarchy.

In recent weeks, the Pope and his closest deputies tried to silence critics and restore faith in the Church’s upper echelons with contradictory pronouncements. Their statements gave the impression that they were testing the effects of possible excuses for the Pope’s tolerance of sex crimes in his former position as the Church’s enforcer of doctrine, as head of the Congregation for the Doctrine of the Faith, and as Pope. Clearly, Church leaders are feeling the urgency of needing to deflect attacks on the Pope, in light of evidence that throughout his career he has consistently failed to defrock, or even strongly condemn, pedophiles: Sex abuse reports spread in Europe; focus on pope | National … The Pope, Pedophilia and the Class StruggleVoice from the Desert » Blog Archive » Piercing a papal shroud …Under attack, Pope says faith will give courage to fight …. The Pope’s spokesmen dismissed the revelations of rampant sex abuse as “Petty Gossip” Pope dismisses ‘petty gossip’ of sexual abuse allegations | World … They attributed the accusations to U.S. media bias Catholic Culture : Latest Headlines : Cardinal Levada decries …. They then equated the Pope’s having to suffer accusations with Jesus’ suffering for humanity Archbishop says Pope is just like Jesus Christ « True Discernment.. They equated accusations of pedophilia to anti-Semitism Vatican slams New York Times “attack” on Pope Benedict in sex … Vatican Official Compares Attacks On Pope Benedict To Anti-Semitism. Jewish groups protested, particularly in light of the Pope’s former membership in the Hitler Youth and his move to sanctify his endorser, Pope John Paul, who had a record of condoning fascism (see herehere and here ). [For commentary on Tikkun, see David Sylvester's "The Deepest Wound: Why the Catholic Church Needs to Heal its Anti-Jewish Legacy - Now!" Ed.]

Church spokesmen tried to blame the problem of pedophile sex abuse on homosexuals, implying that homosexuality is synonymous with pedophilia — that too caused outrage. Next, they stressed the need for forgiveness and repentance, without taking any steps to discipline either abusive priests and bishops or their enablers Pope breaks silence on abuse, urges repentance – Yahoo! News.. The issue was not silenced. Finally on May 12, 2010 the Pope declared that sex abuse is a sin and sickness within the Catholic Church.

It seems significant that the Pope did not declare pedophilia a “crime,” in other words a legal, civil crime, for the justice system to punish.[1]

For the first time, on April 13, 2010 Pope Benedict XVI ordered priests to report their allegations of crimes against children directly to the police, in those states where relevant laws are in effect (New Vatican Guide: Clergy Must Report Sex Abuse – CBS News). One wonders why this order merely references a single specific law which may or may not be on the books, and not a general body of laws against rape, molestation and child abuse?

In addressing those aspects of public outrage aimed directly at himself, Benedict finally took control of The Legionaries of Christ, whose longtime international leader, The Reverend Marcial Maciel Degollado, was the subject of a huge scandal (Vatican Set To Rule On Legionaries Of Christ : NPR). He was known as Father Maciel. Pedophilic sex abuse charges made against Father Maciel by eight priests, along with charges that he fathered several children, had been pending for half a century and noted periodically during that time-span. In 1998, more than four decades after the first reports, the current pope, who was then Cardinal Ratzinger, finally accepted the Maciel case. Within a year, however, he halted the inquiry on the ground that “it isn’t prudent.” Maciel was a hugely successful fund raiser for the Catholic Church which may had had something to do with the Pope’s decision. Eight years later, with Church sex abuse scandals raging in the news media, Pope Benedict banished Father Maciel to a life of prayer with no public statement on The Reverend’s half century of crime (Vatican Set To Rule On Legionaries Of Christ : NPR). The Pope’s takeover of the Legionaries of Christ failed to deflect public outrage and demands for change.

The Church’s crimes

The Catholic Church hierarchy (priests, bishops, cardinals and the Pope himself) has not yet been held accountable, publically and appropriately, for the crimes committed on their watch over several decades: crimes of molestation, rape, assault, and yes, torture of children.

What have been the effects of these crimes on their child victims? A small sample of the Church’s record in this matter conveys the monumentality of this history. The first eruption of accusations occurred in Boston, 2002. Case in point: Father Paul Richard Shanley of Greater Boston.

Example: Shanley

Father Shanley abused scores of children in eight locations, six of those locations in Massachusetts. When reports of the rapes and molestations he had committed[2] came to Church officials’ attention, they simply transferred him to a new post. His male victims ranged in age from six to 21. For example, he raped Kevin Ford in Newton, Massachusetts beginning when Kevin was six years old and continuing for six consecutive years. In other cases, he made proposals of sado-masochistic sex to a young Massachusetts mental patient, and he raped a 15-year-old at the Warwick House for “alienated youth” in Roxbury. Each time the Archdiocese received reports of these crimes, they moved Shanley to another parish with a glowing testament to the competence of his youth ministry. Father Shanley’s final posting was in San Bernardino, California, where Cardinal Law recommended him to Saint Anne’s and Saint John’s Churches as “a priest in good standing.” When more reports of his sex crimes were submitted, he spent a brief time in therapy, paid for by the Church, at Hartford, Connecticut’s Institute for Living. Finally, in 1994, the Boston Archdiocese under Cardinal Law suggested that Shanley be put on medical leave, with full pay, to remove him from sight. At that point, he took up residence at the California resort of his choice: Whispering Palms, a facility owned by a fellow priest named Father White. The Catholic Church financed Shanley’s stay at Whispering Palms which was a clothing optional homosexual resort where sex was practiced around the pool. Father Shanley’s tenure as a priest known by the Church to be a pedophile dated from 1965 to 1994 — almost 30 years. In 1996, citing Father Shanley’s “impressive record,” Cardinal Law of Boston recommended him for retirement-with-full-benefits as a senior priest. In 2002, as scandal consumed the Diocese and dominated news headlines, the police arrested Father Shanley for sex crimes. He was sentenced to 12 to 15 years for rape of a child. He was defrocked in 2004. See a timeline here.

By the time of Shanley’s arrest, Cardinal Law was wanted for questioning in numerous priest-related sex abuse cases. He left Boston for the Vatican (evading media requests for public comment), where he received a salaried Church position and a rent-free apartment in Rome (Vatican Appoints Law Head of Basilica).

Example: Murphy

Another U.S. case is that of Father Lawrence Murphy, who sexually abused 200 deaf boys in Wisconsin over a 24-year period strewn with reports sent to the Vatican about his crimes. Pope Benedict X!V permitted Father Murphy to retire as a paid priest, with full benefits, and exempted him from any investigative proceedings so he could die “with honor” (For Years, Deaf Boys Tried to Tell of Priest’s Abuse – NYTimes.comCNS STORY: Vatican defends action in case of Wisconsin priest abuser). No assistance or compensation was provided to the hundreds of Father Murphy’s deaf victims. Those who had not committed suicide or withdrawn in shame from society, tried valiantly to bring Father Murphy to justice. They reported him to the bishop repeatedly. They contacted the police and the district attorney’s office, which referred their case back to the Church. They picketed the Church. Their only success was in triggering his retirement to his parent’s country home, where he went on to volunteer at a boy’s prison, free to molest others (Vatican Declined to Defrock U.S. Priest Who Abused Boys – NYTimes.comFor Years, Deaf Boys Tried to Tell of Priest’s Abuse – NYTimes.com …. The priest who abused deaf boys for 24 years).

Example: Irish beatings of children

Sex abuse was not the only crime perpetrated against children inside the Catholic Church. Severe beatings often accompanied sex abuse or were administered separately. In these instances, priests were sometimes joined by nuns. The most well-documented recent case involved 35,000 children, who suffered ritual beatings over a period of 60 years at Catholic residential schools in Ireland (Revealed, six decades of ‘ritual’ child abuse: Catholic schools …).

Examples worldwide

Similar examples, far too numerous to cite, exist wherever officials of the Catholic Church have had unfettered access to children, whether in orphanages, programs for troubled youngsters, small group homes, parochial schools, choir academies, etc. Currently, there are cases of sexual abuse in Ireland, Malta, Germany, Austria, The Netherlands, Italy, Switzerland, Poland, France, Belgium, Italy, Chile, Mexico and Spain. These cases are marked by the same sordid program of protection for the abusing Church official, and lifelong torment for the victims.

Holy Fathers have appropriated unto themselves the rights of lords in a feudal world, a world of their — not God’s — creation. As in olden days, the rights of serf-children in their custody within this world are non-existent.

What are the effects on children of crimes committed against them by “men of the cloth”? Priests tend to elicit from the faithful the love, trust and respect one associates with family. And like family, they have special access to children, including the opportunity to influence children’s development. In residential facilities, authorized by the state, they are substitute parents. Perceived as messengers of God whose duties supposedly include hearing confessions, giving advice, giving comfort, moral support and a hand of friendship — priests enjoy power rivaling that of biological fathers. And priests, too, are called “father.”

The sexual crimes committed against children by men addressed officially as “father” are crimes of incest, betrayal, emotional and physical harm. When a child is confronted with the invisibility of his suffering to the protector/abuser, or the man’s indifference to that suffering, the wounds inflicted are as deep as the ocean. The scars left — emotional, relational and sexual scars — never heal completely in the victim’s lifetime. Because children’s egos, intellects and personalities are still in formation, they tend to feel they have perpetrated the crimes of which they are actually the victims. They feel guilty, ashamed, unprotected and helpless, especially if and when they summon the courage to report the abuse and nothing is done. They are vulnerable to repeated abuse because they’re afraid to recognize what happened to them. Feeling powerless to stop it, they dissociate if and when the abuse repeats. They psychologically refuse conscious knowledge of their own experience. Their sex abuse remains as an unconscious, guilty wound. They are prone to depression. They are disproportionately dysfunctional and, as they grow up, may not be able to enjoy their sexuality. They are disproportionately suicidal The Dark Life-Altering Effects of Incest – Associated Content…Impact of child sexual abuse: A review of the research.

The Church long ago ceded to secular government the realms of foreign policy and corporate business practices. The Church has no comment on the practice of usury with regard to credit card bills, or on the fact that the commandment “Thou shalt not kill” exempts governments from its reach. The Church’s influence has noticeably shrunk. The last, bastion it can claim is a personal/family life paradigm of medieval design. But even in that realm, although feudalism lives with the blessing and encouragement of the Holy Fathers, the days of their rule may be numbered.

An end in sight

The oppressed faithful — male and female — have found their voices, which are blending with voices outside the walls of institutional Catholicism. For example, a new generation of reflexively feminist women, who seem to have come by their self-assurance and determination via a different route than the feminist movement of yesterday, are challenging their partners to renegotiate domestic contracts — and a lot of partners are “getting it.”

Perhaps when more people in the U.S. recognize that their “American dream” has been robbed; that vast wealth is accumulating every minute at their expense; that they are being used and abused; that they are not personally to blame for the disintegration of life in their homeland …. perhaps, they too, will lose their shame and call for justice. The men and women whose adolescence and human rights were violated by callous and hypocritical men may show us the way.

[1] I am indebted to Jean Bond for this point.

[2] I recognize that this man has not been tried in a court of law and, thus, not legally been found guilty. However, since there are multiple accusations and the Church and state colluded in keeping these cases within the secret sanctum of the Catholic Church, I presume guilt on the basis of evidence rather than the legal conviction.

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