Believe Her! The Woman Never Lies Myth

Frank S. Zepezauer^*

ABSTRACT: Empirical evidence does not support the widespread belief that women are extremely unlikely to make false accusations of male sexual misconduct.  Rather the research on accusations of rape, sexual harassment, incest, and child sexual abuse indicates that false accusations have become a serious problem.  The motivations involved in making a false report are widely varied and include confusion, outside influence from therapists and others, habitual lying, advantages in custody disputes, financial gain, and the political ideology of radical feminism.
  

Male sexual misconduct — rape, incest, stalking, sexual harassment, child molestation, pornography trafficking — has, according to some observers, become a problem so big that it demands a big solution, not only the reform of our legal system but of our entire society.  Yet the increasingly heated debate over this crisis has focused primarily on how these misbehaviors are defined and how often they occur.  The estimated numbers keep mounting.  We hear that perhaps 31 million women are suffering from some form of rape, 41 million from harassment, 58 million from child sexual abuse, and all 125 million of them — from toddlers to grandmothers — from a toxic "rape culture" that suffocates the feminine spirit.

Much less discussed is how often an allegation of male sexual misconduct is false.  The question seldom enters the debate because, presumably, it had long ago been settled.  Pennsylvania State Law Professor Philip Jenkins (1993), in a review of the "feminist jurisprudence" which leads the sex crisis counterattack, reports that in response to the question its proponents have established an "unchallengeable orthodoxy."  It is that "women did not lie about such victimization, never lied, not out of personal malice, not from mental instability or derangement" (p.19).

Jenkins is not the first to cite this will to believe.  Wendy Kaminer (1993) reported that "it is a primary article of faith among many feminists that women don't lie about rape, ever; they lack the dishonesty gene" (p.67).  Eight years earlier, in 1985, John O'Sullivan discovered a widespread defense of the belief that "no woman would fabricate a rape charge" (p.22).  Feminists themselves admit as much.  Law Professor Susan Estrich stated that "the whole effort at reforming rape laws has been an attack on the premise that women who bring complaints are suspect" (Newsweek, 1985, p.61).  Some feminists believe that even defending that premise is a sex crime.  Alan Dershowitz (1993) reports that he was accused of sexual harassment for discussing in class the possibility of false rape allegations.

Believing the self-proclaimed victim of sexual misconduct has thus evolved from ideological conviction to legal doctrine and, in some jurisdictions, into law.  California now requires that jurors be explicitly told that a rape conviction can be based on the accuser's testimony alone, without corroboration (Associated Press, 1992; Farrell, 1993).  Canada is proposing that a man accused of rape must demonstrate that he received the willing consent of a sexual partner.

These new rules rest on the assumption that women do not lie because they have no motive to lie.  Consequently, as Jenkins (1993) states, the question of the "victim's credibility" has now become "crucial."

Is that credibility warranted, particularly as feminist jurisprudence would want it established, as nearly automatic?  Not if we consult recent history.  And if we do, we will find that we do indeed face a sexual misconduct crisis, but not the one radical feminists now insist is ubiquitous in our society.
  

False Accusations of Rape

Begin with evidence of false accusation of rape, the crime which has become not only the metaphor for all cases of sexual misconduct but for male sexuality itself.  Alan Dershowitz (1991), for example, has further harassed his students by telling them that an annual F.B.I. survey of 1600 law enforcement agencies discovered that 8% of rape charges are completely unfounded.  That figure, which has held steadily over the past decade, is moreover at least twice as high as for any other felony.  Unfounded charges of assault, which like rape is often productive of conflicting testimony, comprise only 1.6% of the total compared to the 8.4% recorded for rape.

Consult also a recent development, DNA testing, which is now becoming routine in rape investigations (Krajik, 1993).  Also routine is the discovery that a third of the DNA scans produce non-matches.  Consequently, a growing number of men are not only gaining acquittals but are also being released from prison.  As with all rape statistics, these figures need careful scrutiny.  Police investigators warn, for example, that a mismatch proves innocence only when the DNA could have come from no one but the assailant and its profile or makeup doesn't match the suspect's.  Even so, the DNA tests, primarily a prosecutorial weapon, have now been added to the arsenal of defense attorneys, and more evidence of false allegation is appearing.

Although useful, the F.B.I. and DNA data on sex crimes result from unstructured number gathering.  More informative, therefore, are the results of a focused study of the false allegation question undertaken by a team headed by Charles P McDowell (McDowell & Hibler, 1985) of the U.S. Air Force Special Studies Division.  Its significance derives not only from its scholarly credentials but also its time of origin, 1984/85, a period during which rape had emerged as a major issue, but before its definition included almost any form of non-consensual sex.

The McDowell team studied 556 rape allegations.  Of that total, 256 could not be conclusively verified as rape.  That left 300 authenticated cases of which 220 were judged to be truthful and 80, or 27%, were judged as false.  In his report Charles McDowell stated that extra rigor was applied to the investigation of potentially false allegations.  To be considered false one or more of the following criteria had to be met: the victim unequivocally admitted to false allegation, indicated deception in a polygraph test, and provided a plausible recantation.  Even by these strict standards, slightly more than one out of four rape charges were judged to be false.

The McDowell report has itself generated controversy even though, when rape is a frequent media topic, it is not widely known.  Its calculations are no doubt problematic enough to raise serious questions.  If, out of 556 rape allegations, 256 could not be conclusively verified as rape, then a large number, 46%, entered a gray area within which more than a few, if not all, of the accusations could have been authentic.  If so, the 27% false allegation figure obtained from the remaining 300 cases could be badly skewed.  Moreover, the study itself focused on a possibly non-representative population of military personnel.

The McDowell team did in fact address these questions in follow-up studies.  They recruited independent reviewers who were given 25 criteria derived from the profiles of the women who openly admitted making a false allegation.  If all three reviewers agreed that the rape allegation was false, it was then listed by that description.  The result: 60% of the accusations were identified as false.  McDowell also took his study outside the military by examining police files from a major midwestern and a southwestern city.  He found that the finding of 60% held (Farrell, 1993, pp. 321-329).

McDowell's data have received qualified confirmation from other investigators.  A survey of seven Washington, D.C. area jurisdictions in the 1991/2 period, for example, revealed that an average of 24% of rape charges were unfounded (Buckley, 1992).  A recently completed study of a small midwestern city was reported by Eugene J. Kanin (1994) of the Department of Sociology and Anthropology at Purdue University.  Kanin concluded that "false rape allegations constitute 41% of the total forcible rape cases reported during this period" (p.81).

Kanin provides significant confirmation of McDowell's findings in several ways.  Kanin's subject, for example, covered a nine-year period — 1978-87 — during which rape had become a highly-politicized issue.  Members of the police department from which the data was taken were therefore sensitive to the kinds of misperceptions about which parties to the dispute had complained.  The city offered a relatively useful model: free of the unrepresentative populations found in resort areas, remote from the extreme crime conditions plaguing large communities, small enough to allow careful investigation of suspicious allegations, but large enough to produce a useful sample of 109 cases.  The investigators also separated "unfounded" from "false" rape allegations, a distinction sometimes blurred in other reports.  Moreover, among the strict guidelines used to determine an allegation's unreliability was McDowell's requirement that only unambiguous recantations be used.

Equally revealing were addenda following Kanin's basic report.  They reported studies in two large Midwestern state universities which covered a three-year period ending in 1988.  The finding of the combined studies was that among a total of 64 reported rapes exactly 50% were false.  Kanin found these results significant because the women in the main report tended to gather in the lower socioeconomic levels, thus raising questions about correlations of false allegation with income and educational status.  After checking figures gathered from university police departments, he therefore reported that "quite unexpectedly then, we find that these university women, when filing a rape complaint, were as likely to file a false as a valid charge."  In addition, Kanin cited still another source (Jay, 1991) which supported findings of high frequency false allegations in the universities.  On the basis of these studies, Kanin felt it reasonable to conclude that "false rape accusations are not uncommon" (p.90).
  

Sexual Harassment

Alan Dershowitz's experience with an esoteric definition of sexual harassment also raises questions about false allegations in this newly-defined but widely publicized crime.  Skeptical checking has revealed that, as with rape, the percentage of unfounded accusations of sexual harassment may reach astonishingly high levels.  That was the claim of Randy Daniels, whose confirmation for New York City's Deputy Mayor was almost derailed by a sexual harassment charge he was able to refute.  To see whether his experience was relatively rare, Daniels checked with the Equal Employment Opportunity Commission.  He found that in 1991, the EEOC investigated or mediated 2119 cases of sexual harassment and found that 59% were determined to have no cause (Daniels, 1993, p. 1).  Since the Hill/Thomas affair they have gone up sharply — up 64% in one year — but so have false allegations, remaining steadily in the plus 50% range.
  

Child Sexual Abuse

This rape and sexual harassment pattern — expanding definitions, rapidly increasing accusations, intensely politicized publicity campaigns, and significantly high percentages of false allegations — has also appeared in still another arena, the agencies which deal with the sexual molestation of children.  With this kind of sexual misconduct the credibility of a third party, the child, becomes a factor, and we hear, in addition to appeals to "believe the woman" an appeal to "believe the child."  We are now learning that children can be manipulated into supplying dramatic testimony of sexual abuse and that in most cases the accusation originates not with the child but with the mother.  Thus the question of credibility once again focuses on women.  As one lawyer put it, "For a lot of these people 'believe the child' is just code.  What they really mean is, 'believe the woman, no questions asked"' (Stein, 1992, p. 160).

To keep this issue in perspective, note three significant facts.  The first is that of the 2,700,000 cases of child abuse reported every year less than 10% involve serious physical abuse and only 8% involve alleged sexual abuse (Schultz, 1989).  The second is that, contrary to the male victimizer/female victim paradigm of feminist ideology, at least as many boys as girls are victimized by child abuse, if not more.  The third is that the majority of child abusers are women, that the most dangerous environment for a child is a home formed by a single mother and her boyfriend, and the safest is formed by a married mother and a husband who is the child's biological father.¹

In many cases allegations of child sexual abuse occur in a nasty divorce made nastier by a custody fight.  It is now so common that it has received scholarly attention and its own acronym, S.A.I.D. (Sexual Allegations in Divorce).  The consensus is that in "S.A.I.D. syndrome" cases the number of such allegations increased so rapidly — up from 7 to 30% in the eighties — that one scholarly team called it an "explosion."  Others, noting how often the guilt of the accused was assumed, used the word "hysteria" and searched for analogies in the Salem and the McCarthy witch hunts (Stein, 1992).

Another consensus is being reached: that the majority of these allegations are false.  Melvin Guyer, Professor of Psychology at the University of Michigan, reports that "in highly contested custody cases where the allegation is made, a number of researchers have found the allegations to be false or unsubstantiated in anywhere from 60 to 80% of those cases " (Felten, 1991).  Another investigative team stated that of 200 cases they studied" about three-fourths have ultimately been adjudicated as no abuse" (Felten, 1991).  Some studies have come in with a lower but still significant estimate.  For example, a 1988 study by the Association of Family and Conciliation Courts said that sexual molestation charges in divorces are probably false one-third of the time (Dvorchak, 1992).

Allegations of child abuse, both divorce related and in general, are flying out so frequently that those who believe themselves victimized by false charges have organized a nationwide support group, VOCAL (Victims Of Child Abuse Laws), which now includes 80 local chapters.  This group refers its members to both informal and professional counsel, sends out a newsletter, and offers access to a rapidly expanding data base.  In 1989, its summary of relevant statistics cited 23 studies which reported findings on both sexual and non-sexual child abuse. Among these, the lowest assessment of false allegation was 35%, the highest 82%, averaging at 66%.
  

Recovered Memories

Those joining VOCAL are finding that an even more dramatic form of child abuse allegation is now sweeping the country.  It originates with a "recovered memory" of sexual atrocity, often involving incest or satanic ritual abuse, usually made by an adult daughter against her father, and almost always discovered in therapy.  This form of allegation made the headlines when celebrities such as Roseanne Arnold, La Toya Jackson, and Suzanne Sommers declared they had suddenly remembered a long repressed victimization.  It is also claiming celebrities among the accused, most notably Cardinal Bernardin of the Roman Catholic Church, which was however later recanted.

In such cases the question of credibility applies not only to the accuser or accused but also to the therapist as well as the therapeutic technique and its supporting theory.  Because cases of recovered memory of abuse have surfaced relatively recently, skeptical criticism is just now beginning to appear in the media although the underlying issues have been under debate for decades.  One result has been the formation of an organization whose title already makes an assertion, the False Memory Syndrome Foundation.  Thus to VOCAL we can add FMSF among the acronyms coined in response to the false allegation problem.

It appears to be widespread.  The FMSF reported that within two years of its founding in 1991, it had built a file of 12,000 families who believed themselves victimized by accusations prompted by false memories.  Eleanor Goldstein (Goldstein & Farmer, 1992) estimates that the actual number of involved families reaches into the tens of thousands.  She also cites data from the National Committee for the Prevention of Child Abuse on the highly inflated estimates of victimization.  Contrary to statements that one in four women have been abused prior to the age of 18, retrospective surveys reveal great variations, from 6 to 62%, which means, Goldstein says, "that we don't have any valid statistics at all" (p.2).

How many of those reports of remembered child abuse, whether in the high or low range, were false?  Several sources suggest that they may match figures on false allegations in reports of rape and sexual harassment.  The National Center for Child Abuse reported that false allegations, which were 35% of all claims in 1975, had by 1993 reached 60% (FMSF Newsletter, 1993).

Other sources suggest that the kind of child abuse caused by satanic ritual cults is almost totally a myth.  There may be a satan and he may have followers but, contrary to widely held belief in the mid-eighties, they did not surface all over middle America.  Where accusations actually led to trials, as in Jordan, Minnesota and in Los Angeles in the McMartin Preschool Case, prosecutors suffered embarrassing defeats.  An extensive New Yorker report of a Washington State case reveals that at least one conviction was indeed achieved.  However, after a careful analysis of the facts, the writer concludes that it was a grievous miscarriage of justice, one more ghastly example of the recovered memory theory gone amok (Wright, 1993).

With regard to recovered memory cases which do not involve satanism, other indications point to a high number of false allegations.  A strong phalanx of professional opinion has raised significant doubts about the veracity of long repressed memories even within a carefully disciplined therapeutic context.  For that reason emphatic warnings are now being issued against their being used in a courtroom — not to mention a press conference — without persuasive corroboration, which, it appears, is often missing.  Some mental health experts make the point more pungently.  Dr. Paul Fink, head of Psychiatry at Albert Einstein Medical Center said, "If a therapist says 70 to 80% of patients remember abuse, I say the therapist ought to be a shoemaker" (Sifford, 1992).  Dr. Richard Ofshe, a member of the FMSF professional advisory board who exposed the proliferating fallacies in the Washington State case, stated that "the incidence of cases in which repressed memories correspond with facts about abuse is as common as Siamese twins joined at the head" (Brzustowicz & Csicsery, 1993, p.8).
  

Motivations of Accusers

Even so, reasonable doubts about a woman's veracity in all these often sensationalized sexual misconduct cases do not necessarily mean that she has deliberately lied.  She may, for example, have suffered from confusion, a problem now proliferating as the definition for sex crimes becomes increasingly complicated and inclusive, leaving all parties struggling with questions about definition and propriety.  Or she may have been affected by emotional instability or mental illness, which one study reported was a factor in 75% of false allegation in divorce cases (Wakefield & Underwager, 1990).  In some cases a woman or her defenders might exaggerate a misdemeanor into a felony or, as happened in Washington state, translate bad parenting into sexual misconduct.

In addition, there has been a tendency to emphasize what a victim felt rather than what happened.  Thus, a woman can truthfully say she felt raped, abused or harassed by behavior which is actually non-criminal.  Moreover, the woman's feelings are often influenced by outside parties with whom she has confided — friends, family members, social workers, therapists, clergymen, rape counselors, lawyers, political activists — any of whom can interpret her emotion as a sign of felonious abuse.

With regard to recovered memory, evidence published by the FMS Foundation suggests that the woman may be as much victimized by therapy or by recovery movement" enthusiasm as by a perpetrator hidden in her subconscious.  Ericka Ingram, the primary accuser in the Washington State case, had come under the influence of both secular and religious counselors.  Their intrusive encouragement helped to loosen a flood of wild charges she leveled against her father and mother as well as two of her father's colleagues.  These realizations have led to an increasing number of lawsuits now being filed by former patients against incompetent or overzealous therapists.  By the same token, among the divorcing wives who file sexual molestation charges against their husbands are some who have been coached by self-serving lawyers.  Columnist Barbara Amiel (1989) stated that "a lawyer is coming close to negligence if he does not advise a client that in child custody cases and property disputes, the mere mention of a child abuse allegation is a significant asset" (p.25).

In The Morning After, Katie Roiphe (1993) reported still another cause of false allegations: political passions generated by activities such as the "Take Back the Night" marches.  She tells about "Mindy" who so wanted to be a "part of this blanket warmth, this woman-centered nonhierarchical empowered notion" that she was "willing to lie" (pp. 40-41).  A similar story was told by a Stanford University professor whose daughter was, he claimed, behind a conspiracy to murder him.  He testified that he had had a good relationship with her until she attended an anti-rape rally.  "She appeared to have gotten swept up ... and was experiencing great emotional distress" (Wykes, 1993).

These mitigating circumstances have often softened the judgment of authorities who confront women guilty of misrepresentation.  In the Washington D.C. area, for example, police send women who lied about rape not to the court room but to a counseling center.  The Princeton woman who accused a fellow student suffered no more than an obligation to write a public apology.  Because of these sometimes compelling reasons for a departure from the truth, many officials hesitate to call a woman a liar.

But it appears, some women with little or no evidence do not hesitate to call a man a rapist.  It also appears that more than a few of them have in fact knowingly and willfully lied.  Regardless of the influences working on Ericka Ingram, for example, there came a point when the evidence openly confounded her story, leaving her with the choice either to persist or recant.  Because she not only persisted but further embellished her story, Richard Ofshe called her an "habitual liar" (Wright, 1993, p.69).  Whether Anita Hill lied about Clarence Thomas still cannot be determined, but David Brock demonstrated that in several other matters she had indeed lied.  And as Charles P. McDowell and other rape allegation researchers have discovered, at least one out of four women in their study population have openly admitted to having lied.

Such disclosures should encourage skepticism toward the now widely held belief that, in accusations of sexual misconduct, women never lie.  The same skepticism should be activated when we hear its supporting explanation: that filing such a charge is so painful that only a truthful woman would proceed.  That belief, although equally strong, is equally suspect.  The research that revealed how many sexual misconduct allegations are false has also revealed how often these unfounded accusations are strongly motivated.

The clearest example of compelling motive can be found in the Sexual Allegation in Divorce (S.A.I.D.) syndrome.  In such cases questionable allegations multiply because the accuser has far more to gain than to lose.  Simply charging a divorcing spouse with child molestation — or wife battering or spousal rape — can turn a hot but evenly balanced custody battle into a rout.  In many cases, the accused husband must vacate what had been the "family" home and submit to prolonged alienation from his children.  He also finds himself ensnared by both the criminal justice and the social service bureaucracies whose conflicting rules of evidence can deny him the presumption of innocence.  In a process that only a Kafka can describe, he must then devote his resources to defending himself rather than pursuing the original divorce litigation.

Even then he may find himself in jail or in court ordered therapy while his accuser has won de facto custody not only of the children but of the house.  Should he eventually win vindication, a process which can literally take years, he may enjoy at best a hollow victory which leaves him financially and emotionally drained, nursing a permanently injured reputation and functioning as an "absent" father with a sparse schedule of controlled visits.  It is no wonder, then, that to express the reality commentators have sometimes used dramatic language, such as "the ultimate weapon" or the "atom bomb."

The impressive results that are so often easily achieved with false allegations in custody disputes suggest the kind of temptations women may feel in other situations.  Among those found to have lied about rape or sexual harassment, for example, a number of motivations have been identified.  The McDowell report listed those they uncovered in declining order of appearance.  "Spite or revenge" and "to compensate for feelings of guilt or shame" accounted for 40% of such allegations (Farrell, 1993, p. 325).  A small percentage were attributed to "mental/emotional disorder or attempted extortion."  In all cases, then, the falsely alleging woman had any of several strong motives to lie.  But, as with the S.A.I.D. syndrome, the most common motive was anger, an emotion which prompts more than a few embattled women to reach for "the ultimate weapon.

Although money gained through extortion ranked low among the motives for false rape allegations, it appears to rank higher when sexual harassment claims prove to be unfounded.  A casual survey of some of the suits that have been filed suggests why.  In the eighties, successful claims often brought damages in the $50,000 to $100,000 range.  After the explosion ignited by the Hill/Thomas case, not only the number of claims but damage awards have skyrocketed.  A clothing store cashier successfully sued her employer for $500,000.  Employees of Stroh's Brewery claimed that the company's commercials, which showed the "Swedish Bikini Team," constituted harassment and sued for damages ranging between $350,000 and $550,000.  In the famous locker room harassment case, Lisa Olson was reported to have received a settlement ranging between $250,00 and $700,000.  Damage claims — and awards — in the millions are becoming more common.

In some cases which were later proved to be false, the financial stakes were particularly high.  One lawyer was charged with coaching six of his clients to "embellish or lie" about some of the incidents on which they based a sexual harassment case.  They had asked for $487,000 (Gonzales, 1993).  Eleven women from the Miss Black America Pageant, after claiming that Mike Tyson had touched them on their rears, filed a $607 million lawsuit against him.  Several of the contestants later admitted they had lied in the hope of getting publicity and cashing in on the award money which would have given them around $20 million each (Farrell, 1993, p.328).

But where extortion does appear, the motivation may be political as well as monetary not only in particular cases but in the growth of the entire sexual misconduct crisis.  Whether it is rape or sexual harassment or divorce-related child molestation or recovered incest memory, many of the investigators eventually mention the influence of ideological feminism.  Katie Roiphe, for example, found feminist politics at work in the phony rape story invented by Mindy, the imaginative Princeton co-ed.  Norman Podhoretz, who wrote about "Rape in Feminist Eyes," attributes the current over-publicized obsession with rape to "the influence of man-hating elements within the (women's) movement (which) has grown so powerful as to have swept all before it" (1992, p.29).  As far back as 1985 John Sullivan attributed the overheated denial of false accusation to attempts to defend the "feminist theory of rape."  And Philip Jenkins (1993), who reported the trend toward automatically-assumed female credibility, stated that it was part of a larger campaign to establish "feminist jurisprudence."

Whatever their motivations in particular cases, there is little doubt that ideological feminists have achieved significant political gains from publicizing the sexual misconduct crisis.  Lisa Olson's feelings of harassment may for example have been genuine, but as the focus for a prolonged media event that established for female reporters an access to locker rooms it was as unpopular with the general public as it was with male athletes.  The real Anita Hill may or may not have been lying, but the Hill/Thomas affair propelled sexual harassment into a hot issue that rapidly generated a subindustry of scholars, consultants, and bureaucrats, prompted a "Year of the Woman" campaign that helped several women into congress, and revived a flagging women's movement.

The same spectacular results may follow from the Tailhook Scandal, which, like Hill/Thomas, is raising serious questions about motive and credibility.  Whether Paula Coughlin's testimony will become as clouded as Anita Hill's, her whistle-blowing has already scuttled the careers of a still growing number of naval officers, not to mention the Secretary of the Navy himself, intensified in-service anti-sexual harassment campaigns, reinforced an already strong feminist presence in the armed forces, and helped soften the military's granitic opposition to women in combat.  These incidents also helped to power a "Violence Against Women" bill through congress which will channel still more millions of government money into women's programs, not to mention winning congressional validation of feminist jurisprudence.  That's a lot of political gain achieved by the words of a few women who suffered little more than an affront to their sensibilities.
  

Conclusions

This growing gap — between the anguish suffered by the victims of traditionally-defined sex crimes and what is suffered by victims of ideologically-defined crimes — suggests that the crisis we face is not the result of a sexual misconduct epidemic but of the crisis mentality itself, an ever more hysterical vision of a "rape culture."  It has a foundation in reality.  In what has become a ritual disclaimer, those who have exposed the surprising number of false allegations of sexual misconduct have also admitted the appalling number of genuine accusations.  And those who have attacked the incompetence, self-interest, and zealotry that has denied the extent of false allegation have also recognized the courage and energy that has exposed the problem of honest allegation begging vainly for belief.  They have therefore applauded the effort to seek for this long ignored injustice both social and legal remediation.

But that effort, carried too far and exploited too often, has generated another gap: between our awareness of the now highly visible victims of sexual misconduct and the almost invisible victims of false allegation.  The lesser known victims have their own stories to tell, enough to reveal another long ignored injustice that demands remediation.  False allegations of sexual misconduct have deprived a rapidly growing number of men and women of their reputations, their fortunes, their children, their livelihood, and their freedom; have wasted the time and money of countless tax-supported agencies; have destroyed not only individuals but entire families and communities; and have left some so desperate that they have taken their lives.

For that reason, in the current revision of our sexual misconduct code, we must retain as a guiding premise the realization that women can lie because we know that, for several reasons, more than a few women have lied, more often than researchers into false allegation had expected, far more often than "rape culture" ideologues have admitted ... too often, in any event, to be ignored by our jurisprudence, feminist or otherwise.
  

Endnote

  
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