Maxwell, Gabrielle And Morris, Allison . Youth justice in New Zealand: A restorative model
Maxwell and Morris claim that the youth justice system in New Zealand represents a fundamental alternative to previous youth justice systems, and that it serves as a model of restorative justice. To make their claims, the authors identify the principles and objectives of that system following key legislation in 1989.
The Youth Justice System
A Maori proverb asks: What is the greatest thing? The answer is: He tangata, he tangata, he tangata - It is the people, it is the people, it is the people. The youth justice system in New Zealand presents a response to young people which turns away from previous systems that failed to touch the hearts and the minds of those who were involved with it. It aims to make young people and families central, to respond to victims and to restore the balance and harmony of the social group by involving victims, young people and family in processes that are culturally sensitive and responsive to their concerns. Both in its principles and processes it can be seen as a model of restorative justice.
Principles and objects of the Children, Young Persons and Their Families Act 1989
The Children, Young Persons and Their Families Act 1989 sets out the objects and principles which are intended to govern state intervention both with respect to children and young persons who are abused or neglected and those who commit offences. Overall, the New Zealand youth justice system represents a move away from a traditional approach that emphasises the imposition of punishment in a relatively formal court system to an approach that emphasises repairing harm and setting in place measures that are likely to prevent reoffending. Thus it is characterised by:
The new system also reflects certain innovatory strategies: the need to be culturally sensitive and appropriate; encouraging families to be involved in all the decision-making processes involving their children; giving young persons themselves a say in how their offending should be responded to; giving victims a voice in negotiations over possible penalties for juvenile offenders; and encouraging decision-making by agreement.
Youth justice in practice
The intention underlying the New Zealand's youth justice system is to encourage the police to adopt low key responses to juvenile offending wherever possible. Thus, as in most jurisdictions now, minor and first offenders are diverted from prosecution by means of an immediate (street) warning. Where further action is thought necessary, the police have to refer the young person to the police Youth Aid Section (a specialist unit) for follow-up. The Youth Aid Section may divert the young person[1] or, when such sanctions have not been successful in the past or when the offending is more serious, refer the young person to a family group conference. During 1998-99, 23% of offences known to the police and attributed to juveniles were noted as having resulted in warnings by the police, a further 60% were noted as having been diverted by Youth Aid[2] and another 6% were noted as being referred directly by Youth Aid for a family group conference. The police cannot refer a young person directly to court unless he or she has been arrested (we deal with this shortly). They must seek a family group conference if they wish the young person to be dealt with in court and, if the family group conference can come up with a satisfactory outcome which is acceptable to all the parties, that is the end of the matter.
Juvenile offenders can only be arrested if certain tightly drawn conditions are met and, in 1998/99, only 12% of the offences attributed to young people resulted in an arrest. It is usually only this arrested group who will subsequently appear in the Youth Court: a branch of the District Court dealing with youth justice issues only. The Youth Court is closed to the public to preserve the confidentiality of its proceedings and routinely appoints a youth advocate (a barrister or solicitor) to represent the young person where the young person does not already have a legal representative. The intention of the 1989 Act was to allow young persons, their families and victims to be involved in the process and to influence outcomes. Thus the Youth Court judge cannot make a disposition unless a family group conference has been held and so the young people arrested will also participate in a family group conference. The Youth Court judge must take into account in its decisions any plan or recommendations put forward by the family group conference.[3] The Youth Court judge has a number of dispositions available to him or her.[4]
Family group conferences
Family group conferences are central to decision making for all moderately serious and serious offences (excepting murder and manslaughter). In all, 18% of all offences known to the police and attributed to juveniles were dealt with through family group conferences in 1998/99. This means that around 5000 family group conferences are held each year.
Family group conferences are made up of the young person who has committed the offence, members of his or her family and whoever the family invites, the victim(s) or their representative, a support person for the victim(s), a representative of the police and the mediator or manager of the process (these are called youth justice co-ordinators and are employees of the Department of Social Welfare). Sometimes a social worker and/ or a lawyer is present. The main goal of a conference is to formulate a plan about how best to deal with the offending. There are three principal components to this:
The family group conference is a meeting between those entitled to attend and takes place in a relatively informal setting. The room is usually arranged with comfortable chairs in a circle. When all are present, there may be a prayer or a blessing depending on the customs of those involved. The youth justice coordinator then welcomes the participants, introduces them and describes the purposes of the meeting. What happens next can vary but usually the police representative reads out the summary of the offence. The young person is asked if he or she agrees with this and any variation in the circumstances of the offending is noted. If the young person does not admit the offence, the meeting progresses no further and the police may consider referring the case to the Youth Court for a hearing. Assuming the young person agrees, the victim, or a spokesperson for the victim, is then usually asked to describe what the offences meant for them. A general discussion of the offence and the circumstances underlying it then occurs and there can be a lot of emotion expressed at this point. It is at this point too that the young person and his or her family may express their remorse for what has happened and make an apology to the victim although more often this occurs later (and sometimes it does not happen at all). Once everybody has discussed what the offending has meant and options for making good the damage, the professionals and the victim leave the family and the young person to meet privately to discuss what plans and recommendation they wish to make to repair the damage and to prevent reoffending. The private family time can take as little as half an hour or much longer. When the family are ready, the others return and the meeting is reconvened. Sometimes this is the point at which the young person and the family apologise to the victim. A spokesperson for the family outlines what they propose and all discuss the proposal. Once there is agreement amongst all present, the details are formally recorded and the conference concludes, sometimes with the sharing of food.
Professionals are expected to play a low key role in the family group conference. The youth justice coordinators task is to ensure that everyone understands what needs to be done, that all the issues that should be canvassed are and that the emotion is managed as constructively as possible. The role of the police is usually limited to describing the offence, and possibly the impact of it on the victim. The police may also voice their concerns if the proposals of the family seem inadequate or excessive. A youth advocate's main role is to advise on legal issues and to protect the young person's rights; they may also express an opinion about the proposed penalties if these seem excessive. The social worker, if present, will normally only provide background information on the young person and participate in supporting the plans of the family and the young person for the future. Practice can, however, vary considerably. Conferences are intended to be flexible and responsive to families, young people and victims. All these values can be breached at times, especially when professionals do not understand or accept their role.[5]
Provided the plans and decisions have been agreed to by all those attending the family group conference and, for court referred cases, are accepted by the Youth Court judge, they are binding on all those involved.[6] The plans are meant to take into account the views of the victims, the need to make the young person accountable for his or her offending and any measure that may prevent future reoffending by enhancing the wellbeing of the offender or strengthening the family. The range of possible sanctions here are limitless (as long as they are agreed to by the parties) and can include an apology, community work, reparation or involvement in a programme. Conferences take much longer than courts to reach resolutions. Just under a third of the conferences in our research (Maxwell and Morris, 1993) took less than an hour, almost a third took between an hour and an hour and a half and more than a quarter took between one and a half and two hours. Around ten percent took more than two hours. Family group conferences can take place wherever the family wish, provided (since an amendment to the 1989 Act in 1994) the victim agrees. Most commonly they are held in rooms in the Department of Social Welfare or in community rooms and occasionally they are held on marae (meeting houses) or in the family's home.
Involving young people in family group conferences
Young people (and families) participating in the New Zealand research on family group conferences were asked a number of key questions: 'Did you feel that you made the decision?' 'How involved were you in reaching the decisions?' and 'In your view, who really decided?' About a third of the young people said that they had felt involved in the process. If responses indicating that the young person felt 'partly' involved are added to this, then we can conclude that nearly half of the young people felt involved in some way. They were able to say what they wanted to and to speak openly without pressure. However, almost a half felt that they had not been involved in the family group conferences and that decisions had been made about them, not with them.[7] Technically, outcomes have to be agreed to by all the parties at the conference, but the young person's voice seemed to have become subsumed within the family's. It needs to be noted, however, that even these relatively low rates of involvement in conferences are still considerably higher than young people's involvement in conventional courts (see, for example, Asquith's (1983) discussion of young people's involvement of juvenile courts in England and children's hearings in Scotland).
Involving families in family group conferences
There is no doubt that families do participate in conferences. In our research (Maxwell and Morris, 1993), almost all conferences had family members present and two fifths had members of the young person's extended family also present (the figure for Maori was much higher: almost 60%). More than two thirds of the families interviewed felt that they had been involved in what had happened at the family group conference and about the same proportion of families identified themselves as the decision-makers, at least in part.[8] Less than a fifth said that they had not felt involved in what happened.
Bringing victims and offenders together for a family group conference was a constructive process for most families. Few families found the presence of the victim to be at all unusual or inappropriate. Moreover, many commented that they viewed the victim's presence positively, because of the possibility of reconciling the victim and the young person, and because the victim's contribution could help teach the young person to accept responsibility and to be accountable for what he or she had done.
Overall, there was little doubt that families preferred the process of family group conferences to the process of courts. Their comments highlighted the participatory nature of the family group conference process and the greater degree of support available to them at the family group conference in contrast to the stress that accompanied a court appearance. As well as feeling more comfortable at the family group conference, families also understood more of what had happened and believed that it provided a more realistic forum for decision-making.
Thus, through conferencing, families are not only expected but enabled to participate in the decisions that are taken when their children offend. In this way, 'making parents responsible' can be given a constructive meaning. Conferencing offers a participatory option that empowers families and allows them, without increasing the stigma or blame, to play a pivotal role in arriving at decisions about their children.
Involving victims in family group conferences
Victims can also feel involved in conferences by being present at the conference. Though our research (Maxwell and Morris, 1993) indicated that victims attended only around half the family group conferences, the reasons for this were related primarily to poor practice: they were not invited, the time was unsuitable for them or they were given inadequate notice of the family group conference. Good practice suggests that victims should be consulted about the time and venue of conferences and informed of them in good time. There will always be a minority of victims who choose not to participate in conferencing but the New Zealand research found that only 6% of victims, when asked, said that they did not wish to meet the offender. This is a clear indicator of victims' willingness, indeed desire, to be involved in these processes.
Our research also showed that, when victims were involved in conferencing, many found this a positive process. About 60% of the victims interviewed described the family group conference they attended as helpful, positive and rewarding. Generally, they said that they were effectively involved in the process and felt better as a result of participating. Victims also commented on two other specific benefits for them. First, it provided them with a voice in determining appropriate outcomes. Second, they were able to meet the offender and the offender's family face-to-face so that they could assess their attitude, understand more why the offence had occurred and assess the likelihood of it recurring.
About a quarter of the victims said that they felt worse as a result of attending the family group conference. There were a variety of reasons for this. The most frequent and perhaps the most important was that the victim did not feel that the young person and/or his or her family were truly sorry. Other less common reasons included the inability of the family and young person to make reparation, the victims' inability to express themselves adequately, the difficulty of communicating cross-culturally, a lack of support, feeling that their concerns had not been adequately listened to and feeling that people were disinterested in or unsympathetic to them. These findings point again to the need for good practice guidelines. Most of the concerns expressed by victims can be addressed through briefing the participants about what to expect at a conference and training the managers of the process to be effective mediators. The concerns raised were not fundamental objections to conferencing per se.
Satisfaction with outcomes
Eighty four percent of the young people and 85% of the parents said that they were satisfied with the outcomes of the family group conference. The levels of satisfaction were high regardless of whether or not the case was referred by the Youth Court or directly by the police. Only a few young people (9%) and parents (11%) actually expressed dissatisfaction with the outcome. For parents, the issues seem to have been either that the young person 'got off too lightly' or, more commonly, that some kind of help or treatment they thought necessary was not offered. For the young people, the issue was almost invariable how their outcome compared with that of co-offenders or, more generally, with their notion of appropriate penalties.
About half of the victims we interviewed[9] said that they were satisfied with the outcomes from conferences. About a third, however, were dissatisfied. For some, this was because they saw the decision of the family group conference as too soft or too harsh. But, more frequently, victims were dissatisfied because the promised arrangements fell down afterwards or they were simply never informed about the eventual outcome of the family group conference. The responsibility for this lay more often with professional staff than with the young person and his or her family. Victims were less satisfied with outcomes than the professionals and families, but even this lower figure is probably higher than the levels of satisfaction victims would express after court hearings and sentences by judges.
Family group conferences and accountability
About 85% of the young people in our sample who took part in family group conferences agreed to carry out what we have called 'active penalties', that is to say community work, reparation and the like. If we add 'apologies' to this, the figure comes closer to 95%. Before the 1989 Act, a similar proportion of young people appeared before the court then as appear now at family group conferences, but only 60% of them received an "active" penalty and apologies to victims were uncommon. On the other hand, custodial or residential penalties are rarely recommended by family group conferences. Thus more young people are made accountable than in the past, but in ways that emphasise restoration.
Issues and Criticisms
Does the youth justice system work?
Positive features
Family group conferences were evaluated in 1990-91 by Maxwell and Morris (1993). At that time, they pointed to conferencing as a more effective and participatory system for victims, young people and families, relatively high levels of satisfaction among everybody involved in the system (except the victims) and major reductions in the numbers appearing in court and in the use of court orders and custodial penalties.[10] They also noted high rates of agreement among all parties recorded at conferences and that victims often received apologies and other forms of recompense. At the same time, there was no evidence of net widening or the widespread use of overly severe penalties.
Negative features
This is not to say that there were no problems in the early days of conferencing. Some victims were dissatisfied with outcomes, sometimes because of the outcomes themselves but more often because of a failure to prepare them appropriately, support them during the conference or inform them after the conference of what was happening. Criticisms were made of many aspects of practice: for instance, there has been only limited training provided for many of the professionals managing the system and a lack of best practice guidelines.[11]
The number of youth justice coordinators and social workers managing the process of family group conferencing increased in the early years following the introduction of the new system in 1989 but from the mid 1990s their number has remained stable or declined (Maxwell and Morris, 1996). It is not surprising, therefore, that the number of family group conferences has risen little since the mid 1990s. At the same time, the numbers of young people offending have risen.
Another result of limited staff resources in the youth justice sector is the capacity of the system to improve those aspects of practice that have been criticised, especially with respect to the preparation for family group conference of victims, informing victims about the outcomes of family group conferences and monitoring these outcomes to ensure that families and young people have completed those aspects of the plan involving them and that professionals have made the arrangements which they agreed to put in place. Information is not available on these issues but many of those working in the sector feel that little has changed since the early 1990s. There has also been a lack of a planned approach to monitoring and assessing systems' issues.
Maxwell (1995) analysed funding available for financing family group conferences and showed a dramatic decline over a period when the actual number of conferences had increased. More recent information is not available due to changes in financial accounting practices.
Compounding the difficulties created by limited funding through family group conferences for interventions is the limited availability of services within New Zealand for children, young people and their families. Despite the fact that the objectives of the Children, Young Persons and Their Families Act 1989 include the provision of accessible and culturally appropriate services for children and young people and strengthening their families, since the Act there has been, as already noted, a decline in the public health, education and welfare budgets. A major casualty of budgetary constraints has been the provision of services for children and young people. Even in those communities that still offer programmes to deal with alcohol and drug abuse, few can provide specialised services for young people. A number of reports (Werry, 1996; McGeorge, 1995) also point to the declining availability of mental health services throughout the country and the inadequacy of those services to meet the needs of the child and adolescent most at risk.
There are relatively few effective intervention programmes for young offenders, especially those who have been involved in repeat or serious offences. In part, this reflects the general limitations on services for young people; in part, this reflects the lack of resourcing for interventions recommended by family group conferences; and, in part, this reflects the lack of a well developed history of service provision in this area.
There are few alternatives in the community for vocational skills training or for a graduated return to education. Pre-employment courses are often offered only for a limited time frame and few young people move on from them to employment. Some young people to whom we have spoken speak cynically of being recycled through several of these (Morris et al, 1998). Within the community there are no specialised courses that focus on preventing reoffending. Marae placements have been developed for young people which focus on general skills and cultural knowledge but the opportunities for placements on these programmes have been limited by the lack of funds. There have been a number of demonstration sex offender programmes but ongoing funding is mostly available only for older men rather than for specialist programmes for young people. A residential programme for young sex offenders has taken several years to initiate and there is still community opposition to the proposed site.
Even within the residential facilities, programme delivery has been hampered by restricted budgets and a high turnover of residential staff. Concerns have been expressed about the lack of follow up for young people once they return to the community.
Police views
Opposition by front line police has been a problem for the new system from its inception. The argument has been that the Children, Young Persons and Their Families Act 1989 is a soft option and that the policing of young people has been undermined by the aspects of the system that have been introduced to strengthen the protection of the rights of young people when interviewed and arrested (Maxwell and Morris, 1993). These attitudes are not shared by those in the police who are closest to the youth justice system, the Youth Aid officers (Cheer, 1998), and there have been changes in general police attitudes with improved training of recruits but the lack of faith of front line police who are gatekeepers remains a problem (Potaka, 1997).
Understanding reoffending
A further criticism is that the system does not deal adequately with persistent offenders and it has failed to reduce offending in general and reoffending in particular. This criticism is inappropriate and unrealistic. More than 80% of young people coming into the system are first offenders (Maxwell and Morris, 1993). Furthermore, it is, of course, impossible to expect a system of processing young people to prevent re-offending. Understanding reoffending is complex and depends on factors outside the control of the justice system.
Morris and Maxwell (1997), Maxwell and Morris (2000) have examined the impact of the system on reoffending in two papers. These found that, of those who attended conferences, 29% remained conviction free six years later and 28% could be classified as persistently reconvicted. Factors which differentiated these two groups were identified. These included factors already identified by previous research such as offence characteristics, childhood and family circumstances and subsequent life events. However, they also included some important family group conference characteristics including variables that indicate that when a young person experiences a sense of remorse and makes some attempt at restoration they are less likely to be reconvicted. On the other hand, when young people and their families feel shamed by the process, the young people are more likely to be in the persistent reconvicted group.
Conclusion
The New Zealand youth justice system has been the centre of wide-spread international interest among professionals, policy advisers, and academics and has been imitated by other jurisdictions. Various versions of conferencing have been developed or trialled in countries as diverse as Ireland, England, Sweden, South Africa, Singapore, Canada and the United States. Several Australian states have also experimented extensively with conferencing and three states have incorporated the model in their legislation. Legislation to introduce conferencing has also been passed in Ireland and Sweden.
While imitation could be said to be an indicator of success, more substantial data are available from New Zealand and elsewhere (Hudson et al, 1996) to indicate that conferencing systems are certainly not responsible for increases in offending and reoffending, that high proportions of those actively participating are satisfied with outcomes and that victims can participate in a process that has the potential for restorative outcomes. In New Zealand, the system has influenced police youth aid thinking and encouraged their active participation in arranging diversionary solutions. Nationwide implementation of conferencing for relatively serious offences also provides evidence that restorative justice ideas can be incorporated effectively in modern criminal justice systems.
Critiques of social policy in New Zealand (Shirley et al, 1997) suggest that policy has not been effective in providing sufficient support for the families of young offenders to ameliorate the circumstances that place their children at risk. On closer inspection, the achievements of the youth justice system in New Zealand are mixed. Lessons can be learnt from the new Zealand experience about the need to resource the system, the need to monitor practice and the need to evaluate outcomes. The potential and power of conferencing to provide a new and more effective process for responding to young people who offend depends on a total system of delivery and New Zealand has not achieved that. The message from this analysis is that it is important to focus not only on the decision-making system, but also on the provision of the services needed to ensure good outcomes for children and young people.
References
Cheer, M. (1998). Youth Aid officers' views on training. Criminology: Aotearoa/New Zealand. No. 9; 12.
Doolan, M. (1988) From Welfare to Justice. (Towards new social work practice with young offenders: An overseas study tour report) Wellington: Department of Social Welfare.
Hudson, J., Morris, A., Maxwell, G. & Galaway, B. (1996). Family Group Conferences: Perspectives on Policy and Practice. Annandale: The Federation Press.
Maxwell, G. (1995). Rights and responsibilities: Youth justice. In Rights and responsibilities (pp 61-69). Wellington: International Year of the family Committee in association with the Office of the Commissioner for Children.
Maxwell, G.M. and Carroll-Lind, J. (1996). Children's Experience of Violence. Wellington: Office of the Commissioner for Children.
Maxwell, G.M. and Morris, A. (1993). Families Victims and Culture: Youth Justice in New Zealand. Wellington: Institute of Criminology, Victoria University of Wellington and Social Policy Agency.
Maxwell, G.M. and Morris, A. (1996). Research on Family Group Conferences with Young Offenders. In: Hudson, J., Morris, A., Maxwell, G. & Galaway, B. Family Group Conferences: Perspectives on Policy and Practice. Annandale: The Federation Press.
Maxwell, G.M. and Morris, A. (1993). Families Victims and Culture: Youth Justice in New Zealand. Wellington: Institute of Criminology, Victoria University of Wellington and Social Policy Agency.
Maxwell, G.M. and Morris, A. (2000). Understanding Reoffending: Full report. Wellington: Institute of Criminology, Victoria University of Wellington.
McGeorge, P. (1995) Unpublished report to the Ministry of Health on services needed for children and adolescents.
Morris, A. and Maxwell, G. (1997) Family group conferences and convictions. Occasional paper No. 5. Wellington: Institute of Criminology, Victoria University of Wellington.
Morris, A. and Young, W. (1987) Juvenile justice in New Zealand: Policy and practice, Studies Series 1, Wellington: Institute of Criminology
Morris, A. Maxwell, G. and Shepherd, P. (1997a). Being a youth advocate: An analysis of their role and responsibilities. Wellington: Institute of Criminology for Victoria Link.
Potaka, L. (1997) Police views on the Children, Young Persons and Their Families Act 1989. Criminology: Aotearoa/New Zealand. No. 8; 6-7.
Shirley, I., Koopmnan-Boyden, P, Pool, I and St John, S. (1997) Family Change and Family Policies: New Zealand. In Kamerman, S. & Kahn, A., Family Change and Family Policies in Great Britain, Canada, New Zealand and the United States. Oxford: Clarendon.
Spier, P. (1997). Conviction and Sentencing of offenders in New Zealand: 1987 to 1996. Wellington: Ministry of Justice.
Werry, J.S. (1996). Mental health services for children and young people. Wellington: Ministry of Health.
Acknowledgments
This paper has been updated from one published by the Canadian Research Insititue for Law and the Family in the proceedings of "Youth Justice System Conference: An International Persepctive on Problems and Solutions"; Ottawa 1998. We would like to acknowledge the help of the New Zealand Police who have supplied data for this paper.
[1] Diversion can include a warning in writing or in the presence of the young person's parents, an apology to the victim, or the imposition of an additional sanction (for example, some community work)
[2] Youth aid officers making use of informal diversionary procedures are informed by the general principles of the Children Young Persons and Their Families Act 1989. Thus decisions are taken in consultation with victims and families.
[3] People in other jurisdictions often ask about whether or not there are certain cases for which family group conferences are not appropriate, for instance very serious offences. In New Zealand, all cases involving young offenders except murder and mansaughter will have a family group conference so that the views of families and victims can be heard. However, for those cases which go to the Youth Court, the judge can review the case and make a different disposition from that recommended if there are grounds for this. The Youth Court judge can refer the most serious offences on to the adults courts for sentence. The Youth Court will also decide the outcome when participants at the conference fail to agree. Cases of murder and manslaughter are dealt with in the adult courts.
[4] The orders in the Youth Court which are most frequently used include discharge without further order or penalty, reparation, community work, supervision with activity (includes a plan covering all acitivites for up to 6 months), supervision with residence (a residential programme for up to 3 months which can be followed by up to 6 months supervision) and transfer to the District Court for sentence (if over the age of 15 years).
[5] One example of the confusion that can exist about professional roles is provided in a recent analysis of the role of youth advocates (Morris et al, 1997).
[6] Almost all family group conferences result in agreed outcomes: the figure for 1996 was 86%. This has hardly changed over the years since the introduction of family group conferences. It is also unusual for Youth Court judges to disagree with the recommendations made to them from family group conferences.
[7] Although about a quarter of the young people said they did not know who had decided the outcome, the group most frequently identified by them as the decision-makers was their family. This was stated by about a third.
[8] The professionals alone were identified as the decision-makers by 15% of the families. These professionals seemed not to have accepted a redefined role for themselves: information providers and support givers rather than decision-makers. This could be resolved by better briefing of professionals about their roles and better training of them in the objectives of conferencing.
[9] These interviews sometimes took place soon after the family group conference but most of them occurred about two to three months later.
[10] There was a significant drop in the numbe rof young people appearing in courts between 1989 and 1990: from 8193 to 2352. Since then, there has been a gradual increase in the number of cases getting to court, but, even so, the 1996 figure of 3908 - the highest number since the Act was introduced - is still 64% less than in 1987.
[11] In 1997, Morris and Maxwell (1997a) produced a report on the role of youth advocates which sets out best practice guidelines and has formed the basis of a training programme for all youth advocates. It is hoped that best practice guidelines and training based on them will also be developed for youth justice coordinators and social workers but this has yet to occur.
A Maori proverb asks: What is the greatest thing? The answer is: He tangata, he tangata, he tangata - It is the people, it is the people, it is the people. The youth justice system in New Zealand presents a response to young people which turns away from previous systems that failed to touch the hearts and the minds of those who were involved with it. It aims to make young people and families central, to respond to victims and to restore the balance and harmony of the social group by involving victims, young people and family in processes that are culturally sensitive and responsive to their concerns. Both in its principles and processes it can be seen as a model of restorative justice.
Principles and objects of the Children, Young Persons and Their Families Act 1989
The Children, Young Persons and Their Families Act 1989 sets out the objects and principles which are intended to govern state intervention both with respect to children and young persons who are abused or neglected and those who commit offences. Overall, the New Zealand youth justice system represents a move away from a traditional approach that emphasises the imposition of punishment in a relatively formal court system to an approach that emphasises repairing harm and setting in place measures that are likely to prevent reoffending. Thus it is characterised by:
- an emphasis on accountability and responsibility;
- a preference for diversion from formal procedures and for deinstitutionalisation and community based penalties.
The new system also reflects certain innovatory strategies: the need to be culturally sensitive and appropriate; encouraging families to be involved in all the decision-making processes involving their children; giving young persons themselves a say in how their offending should be responded to; giving victims a voice in negotiations over possible penalties for juvenile offenders; and encouraging decision-making by agreement.
Youth justice in practice
The intention underlying the New Zealand's youth justice system is to encourage the police to adopt low key responses to juvenile offending wherever possible. Thus, as in most jurisdictions now, minor and first offenders are diverted from prosecution by means of an immediate (street) warning. Where further action is thought necessary, the police have to refer the young person to the police Youth Aid Section (a specialist unit) for follow-up. The Youth Aid Section may divert the young person[1] or, when such sanctions have not been successful in the past or when the offending is more serious, refer the young person to a family group conference. During 1998-99, 23% of offences known to the police and attributed to juveniles were noted as having resulted in warnings by the police, a further 60% were noted as having been diverted by Youth Aid[2] and another 6% were noted as being referred directly by Youth Aid for a family group conference. The police cannot refer a young person directly to court unless he or she has been arrested (we deal with this shortly). They must seek a family group conference if they wish the young person to be dealt with in court and, if the family group conference can come up with a satisfactory outcome which is acceptable to all the parties, that is the end of the matter.
Juvenile offenders can only be arrested if certain tightly drawn conditions are met and, in 1998/99, only 12% of the offences attributed to young people resulted in an arrest. It is usually only this arrested group who will subsequently appear in the Youth Court: a branch of the District Court dealing with youth justice issues only. The Youth Court is closed to the public to preserve the confidentiality of its proceedings and routinely appoints a youth advocate (a barrister or solicitor) to represent the young person where the young person does not already have a legal representative. The intention of the 1989 Act was to allow young persons, their families and victims to be involved in the process and to influence outcomes. Thus the Youth Court judge cannot make a disposition unless a family group conference has been held and so the young people arrested will also participate in a family group conference. The Youth Court judge must take into account in its decisions any plan or recommendations put forward by the family group conference.[3] The Youth Court judge has a number of dispositions available to him or her.[4]
Family group conferences
Family group conferences are central to decision making for all moderately serious and serious offences (excepting murder and manslaughter). In all, 18% of all offences known to the police and attributed to juveniles were dealt with through family group conferences in 1998/99. This means that around 5000 family group conferences are held each year.
Family group conferences are made up of the young person who has committed the offence, members of his or her family and whoever the family invites, the victim(s) or their representative, a support person for the victim(s), a representative of the police and the mediator or manager of the process (these are called youth justice co-ordinators and are employees of the Department of Social Welfare). Sometimes a social worker and/ or a lawyer is present. The main goal of a conference is to formulate a plan about how best to deal with the offending. There are three principal components to this:
- ascertaining whether or not the young person admits the offence;
- information sharing among all the parties at the conference about the nature of the offence, the effects of the offence on the victims, the reasons for the offending, any prior offending by the young person and so on;
- deciding the outcome or recommendation.
The family group conference is a meeting between those entitled to attend and takes place in a relatively informal setting. The room is usually arranged with comfortable chairs in a circle. When all are present, there may be a prayer or a blessing depending on the customs of those involved. The youth justice coordinator then welcomes the participants, introduces them and describes the purposes of the meeting. What happens next can vary but usually the police representative reads out the summary of the offence. The young person is asked if he or she agrees with this and any variation in the circumstances of the offending is noted. If the young person does not admit the offence, the meeting progresses no further and the police may consider referring the case to the Youth Court for a hearing. Assuming the young person agrees, the victim, or a spokesperson for the victim, is then usually asked to describe what the offences meant for them. A general discussion of the offence and the circumstances underlying it then occurs and there can be a lot of emotion expressed at this point. It is at this point too that the young person and his or her family may express their remorse for what has happened and make an apology to the victim although more often this occurs later (and sometimes it does not happen at all). Once everybody has discussed what the offending has meant and options for making good the damage, the professionals and the victim leave the family and the young person to meet privately to discuss what plans and recommendation they wish to make to repair the damage and to prevent reoffending. The private family time can take as little as half an hour or much longer. When the family are ready, the others return and the meeting is reconvened. Sometimes this is the point at which the young person and the family apologise to the victim. A spokesperson for the family outlines what they propose and all discuss the proposal. Once there is agreement amongst all present, the details are formally recorded and the conference concludes, sometimes with the sharing of food.
Professionals are expected to play a low key role in the family group conference. The youth justice coordinators task is to ensure that everyone understands what needs to be done, that all the issues that should be canvassed are and that the emotion is managed as constructively as possible. The role of the police is usually limited to describing the offence, and possibly the impact of it on the victim. The police may also voice their concerns if the proposals of the family seem inadequate or excessive. A youth advocate's main role is to advise on legal issues and to protect the young person's rights; they may also express an opinion about the proposed penalties if these seem excessive. The social worker, if present, will normally only provide background information on the young person and participate in supporting the plans of the family and the young person for the future. Practice can, however, vary considerably. Conferences are intended to be flexible and responsive to families, young people and victims. All these values can be breached at times, especially when professionals do not understand or accept their role.[5]
Provided the plans and decisions have been agreed to by all those attending the family group conference and, for court referred cases, are accepted by the Youth Court judge, they are binding on all those involved.[6] The plans are meant to take into account the views of the victims, the need to make the young person accountable for his or her offending and any measure that may prevent future reoffending by enhancing the wellbeing of the offender or strengthening the family. The range of possible sanctions here are limitless (as long as they are agreed to by the parties) and can include an apology, community work, reparation or involvement in a programme. Conferences take much longer than courts to reach resolutions. Just under a third of the conferences in our research (Maxwell and Morris, 1993) took less than an hour, almost a third took between an hour and an hour and a half and more than a quarter took between one and a half and two hours. Around ten percent took more than two hours. Family group conferences can take place wherever the family wish, provided (since an amendment to the 1989 Act in 1994) the victim agrees. Most commonly they are held in rooms in the Department of Social Welfare or in community rooms and occasionally they are held on marae (meeting houses) or in the family's home.
Involving young people in family group conferences
Young people (and families) participating in the New Zealand research on family group conferences were asked a number of key questions: 'Did you feel that you made the decision?' 'How involved were you in reaching the decisions?' and 'In your view, who really decided?' About a third of the young people said that they had felt involved in the process. If responses indicating that the young person felt 'partly' involved are added to this, then we can conclude that nearly half of the young people felt involved in some way. They were able to say what they wanted to and to speak openly without pressure. However, almost a half felt that they had not been involved in the family group conferences and that decisions had been made about them, not with them.[7] Technically, outcomes have to be agreed to by all the parties at the conference, but the young person's voice seemed to have become subsumed within the family's. It needs to be noted, however, that even these relatively low rates of involvement in conferences are still considerably higher than young people's involvement in conventional courts (see, for example, Asquith's (1983) discussion of young people's involvement of juvenile courts in England and children's hearings in Scotland).
Involving families in family group conferences
There is no doubt that families do participate in conferences. In our research (Maxwell and Morris, 1993), almost all conferences had family members present and two fifths had members of the young person's extended family also present (the figure for Maori was much higher: almost 60%). More than two thirds of the families interviewed felt that they had been involved in what had happened at the family group conference and about the same proportion of families identified themselves as the decision-makers, at least in part.[8] Less than a fifth said that they had not felt involved in what happened.
Bringing victims and offenders together for a family group conference was a constructive process for most families. Few families found the presence of the victim to be at all unusual or inappropriate. Moreover, many commented that they viewed the victim's presence positively, because of the possibility of reconciling the victim and the young person, and because the victim's contribution could help teach the young person to accept responsibility and to be accountable for what he or she had done.
Overall, there was little doubt that families preferred the process of family group conferences to the process of courts. Their comments highlighted the participatory nature of the family group conference process and the greater degree of support available to them at the family group conference in contrast to the stress that accompanied a court appearance. As well as feeling more comfortable at the family group conference, families also understood more of what had happened and believed that it provided a more realistic forum for decision-making.
Thus, through conferencing, families are not only expected but enabled to participate in the decisions that are taken when their children offend. In this way, 'making parents responsible' can be given a constructive meaning. Conferencing offers a participatory option that empowers families and allows them, without increasing the stigma or blame, to play a pivotal role in arriving at decisions about their children.
Involving victims in family group conferences
Victims can also feel involved in conferences by being present at the conference. Though our research (Maxwell and Morris, 1993) indicated that victims attended only around half the family group conferences, the reasons for this were related primarily to poor practice: they were not invited, the time was unsuitable for them or they were given inadequate notice of the family group conference. Good practice suggests that victims should be consulted about the time and venue of conferences and informed of them in good time. There will always be a minority of victims who choose not to participate in conferencing but the New Zealand research found that only 6% of victims, when asked, said that they did not wish to meet the offender. This is a clear indicator of victims' willingness, indeed desire, to be involved in these processes.
Our research also showed that, when victims were involved in conferencing, many found this a positive process. About 60% of the victims interviewed described the family group conference they attended as helpful, positive and rewarding. Generally, they said that they were effectively involved in the process and felt better as a result of participating. Victims also commented on two other specific benefits for them. First, it provided them with a voice in determining appropriate outcomes. Second, they were able to meet the offender and the offender's family face-to-face so that they could assess their attitude, understand more why the offence had occurred and assess the likelihood of it recurring.
About a quarter of the victims said that they felt worse as a result of attending the family group conference. There were a variety of reasons for this. The most frequent and perhaps the most important was that the victim did not feel that the young person and/or his or her family were truly sorry. Other less common reasons included the inability of the family and young person to make reparation, the victims' inability to express themselves adequately, the difficulty of communicating cross-culturally, a lack of support, feeling that their concerns had not been adequately listened to and feeling that people were disinterested in or unsympathetic to them. These findings point again to the need for good practice guidelines. Most of the concerns expressed by victims can be addressed through briefing the participants about what to expect at a conference and training the managers of the process to be effective mediators. The concerns raised were not fundamental objections to conferencing per se.
Satisfaction with outcomes
Eighty four percent of the young people and 85% of the parents said that they were satisfied with the outcomes of the family group conference. The levels of satisfaction were high regardless of whether or not the case was referred by the Youth Court or directly by the police. Only a few young people (9%) and parents (11%) actually expressed dissatisfaction with the outcome. For parents, the issues seem to have been either that the young person 'got off too lightly' or, more commonly, that some kind of help or treatment they thought necessary was not offered. For the young people, the issue was almost invariable how their outcome compared with that of co-offenders or, more generally, with their notion of appropriate penalties.
About half of the victims we interviewed[9] said that they were satisfied with the outcomes from conferences. About a third, however, were dissatisfied. For some, this was because they saw the decision of the family group conference as too soft or too harsh. But, more frequently, victims were dissatisfied because the promised arrangements fell down afterwards or they were simply never informed about the eventual outcome of the family group conference. The responsibility for this lay more often with professional staff than with the young person and his or her family. Victims were less satisfied with outcomes than the professionals and families, but even this lower figure is probably higher than the levels of satisfaction victims would express after court hearings and sentences by judges.
Family group conferences and accountability
About 85% of the young people in our sample who took part in family group conferences agreed to carry out what we have called 'active penalties', that is to say community work, reparation and the like. If we add 'apologies' to this, the figure comes closer to 95%. Before the 1989 Act, a similar proportion of young people appeared before the court then as appear now at family group conferences, but only 60% of them received an "active" penalty and apologies to victims were uncommon. On the other hand, custodial or residential penalties are rarely recommended by family group conferences. Thus more young people are made accountable than in the past, but in ways that emphasise restoration.
Issues and Criticisms
Does the youth justice system work?
Positive features
Family group conferences were evaluated in 1990-91 by Maxwell and Morris (1993). At that time, they pointed to conferencing as a more effective and participatory system for victims, young people and families, relatively high levels of satisfaction among everybody involved in the system (except the victims) and major reductions in the numbers appearing in court and in the use of court orders and custodial penalties.[10] They also noted high rates of agreement among all parties recorded at conferences and that victims often received apologies and other forms of recompense. At the same time, there was no evidence of net widening or the widespread use of overly severe penalties.
Negative features
This is not to say that there were no problems in the early days of conferencing. Some victims were dissatisfied with outcomes, sometimes because of the outcomes themselves but more often because of a failure to prepare them appropriately, support them during the conference or inform them after the conference of what was happening. Criticisms were made of many aspects of practice: for instance, there has been only limited training provided for many of the professionals managing the system and a lack of best practice guidelines.[11]
The number of youth justice coordinators and social workers managing the process of family group conferencing increased in the early years following the introduction of the new system in 1989 but from the mid 1990s their number has remained stable or declined (Maxwell and Morris, 1996). It is not surprising, therefore, that the number of family group conferences has risen little since the mid 1990s. At the same time, the numbers of young people offending have risen.
Another result of limited staff resources in the youth justice sector is the capacity of the system to improve those aspects of practice that have been criticised, especially with respect to the preparation for family group conference of victims, informing victims about the outcomes of family group conferences and monitoring these outcomes to ensure that families and young people have completed those aspects of the plan involving them and that professionals have made the arrangements which they agreed to put in place. Information is not available on these issues but many of those working in the sector feel that little has changed since the early 1990s. There has also been a lack of a planned approach to monitoring and assessing systems' issues.
Maxwell (1995) analysed funding available for financing family group conferences and showed a dramatic decline over a period when the actual number of conferences had increased. More recent information is not available due to changes in financial accounting practices.
Compounding the difficulties created by limited funding through family group conferences for interventions is the limited availability of services within New Zealand for children, young people and their families. Despite the fact that the objectives of the Children, Young Persons and Their Families Act 1989 include the provision of accessible and culturally appropriate services for children and young people and strengthening their families, since the Act there has been, as already noted, a decline in the public health, education and welfare budgets. A major casualty of budgetary constraints has been the provision of services for children and young people. Even in those communities that still offer programmes to deal with alcohol and drug abuse, few can provide specialised services for young people. A number of reports (Werry, 1996; McGeorge, 1995) also point to the declining availability of mental health services throughout the country and the inadequacy of those services to meet the needs of the child and adolescent most at risk.
There are relatively few effective intervention programmes for young offenders, especially those who have been involved in repeat or serious offences. In part, this reflects the general limitations on services for young people; in part, this reflects the lack of resourcing for interventions recommended by family group conferences; and, in part, this reflects the lack of a well developed history of service provision in this area.
There are few alternatives in the community for vocational skills training or for a graduated return to education. Pre-employment courses are often offered only for a limited time frame and few young people move on from them to employment. Some young people to whom we have spoken speak cynically of being recycled through several of these (Morris et al, 1998). Within the community there are no specialised courses that focus on preventing reoffending. Marae placements have been developed for young people which focus on general skills and cultural knowledge but the opportunities for placements on these programmes have been limited by the lack of funds. There have been a number of demonstration sex offender programmes but ongoing funding is mostly available only for older men rather than for specialist programmes for young people. A residential programme for young sex offenders has taken several years to initiate and there is still community opposition to the proposed site.
Even within the residential facilities, programme delivery has been hampered by restricted budgets and a high turnover of residential staff. Concerns have been expressed about the lack of follow up for young people once they return to the community.
Police views
Opposition by front line police has been a problem for the new system from its inception. The argument has been that the Children, Young Persons and Their Families Act 1989 is a soft option and that the policing of young people has been undermined by the aspects of the system that have been introduced to strengthen the protection of the rights of young people when interviewed and arrested (Maxwell and Morris, 1993). These attitudes are not shared by those in the police who are closest to the youth justice system, the Youth Aid officers (Cheer, 1998), and there have been changes in general police attitudes with improved training of recruits but the lack of faith of front line police who are gatekeepers remains a problem (Potaka, 1997).
Understanding reoffending
A further criticism is that the system does not deal adequately with persistent offenders and it has failed to reduce offending in general and reoffending in particular. This criticism is inappropriate and unrealistic. More than 80% of young people coming into the system are first offenders (Maxwell and Morris, 1993). Furthermore, it is, of course, impossible to expect a system of processing young people to prevent re-offending. Understanding reoffending is complex and depends on factors outside the control of the justice system.
Morris and Maxwell (1997), Maxwell and Morris (2000) have examined the impact of the system on reoffending in two papers. These found that, of those who attended conferences, 29% remained conviction free six years later and 28% could be classified as persistently reconvicted. Factors which differentiated these two groups were identified. These included factors already identified by previous research such as offence characteristics, childhood and family circumstances and subsequent life events. However, they also included some important family group conference characteristics including variables that indicate that when a young person experiences a sense of remorse and makes some attempt at restoration they are less likely to be reconvicted. On the other hand, when young people and their families feel shamed by the process, the young people are more likely to be in the persistent reconvicted group.
Conclusion
The New Zealand youth justice system has been the centre of wide-spread international interest among professionals, policy advisers, and academics and has been imitated by other jurisdictions. Various versions of conferencing have been developed or trialled in countries as diverse as Ireland, England, Sweden, South Africa, Singapore, Canada and the United States. Several Australian states have also experimented extensively with conferencing and three states have incorporated the model in their legislation. Legislation to introduce conferencing has also been passed in Ireland and Sweden.
While imitation could be said to be an indicator of success, more substantial data are available from New Zealand and elsewhere (Hudson et al, 1996) to indicate that conferencing systems are certainly not responsible for increases in offending and reoffending, that high proportions of those actively participating are satisfied with outcomes and that victims can participate in a process that has the potential for restorative outcomes. In New Zealand, the system has influenced police youth aid thinking and encouraged their active participation in arranging diversionary solutions. Nationwide implementation of conferencing for relatively serious offences also provides evidence that restorative justice ideas can be incorporated effectively in modern criminal justice systems.
Critiques of social policy in New Zealand (Shirley et al, 1997) suggest that policy has not been effective in providing sufficient support for the families of young offenders to ameliorate the circumstances that place their children at risk. On closer inspection, the achievements of the youth justice system in New Zealand are mixed. Lessons can be learnt from the new Zealand experience about the need to resource the system, the need to monitor practice and the need to evaluate outcomes. The potential and power of conferencing to provide a new and more effective process for responding to young people who offend depends on a total system of delivery and New Zealand has not achieved that. The message from this analysis is that it is important to focus not only on the decision-making system, but also on the provision of the services needed to ensure good outcomes for children and young people.
References
Cheer, M. (1998). Youth Aid officers' views on training. Criminology: Aotearoa/New Zealand. No. 9; 12.
Doolan, M. (1988) From Welfare to Justice. (Towards new social work practice with young offenders: An overseas study tour report) Wellington: Department of Social Welfare.
Hudson, J., Morris, A., Maxwell, G. & Galaway, B. (1996). Family Group Conferences: Perspectives on Policy and Practice. Annandale: The Federation Press.
Maxwell, G. (1995). Rights and responsibilities: Youth justice. In Rights and responsibilities (pp 61-69). Wellington: International Year of the family Committee in association with the Office of the Commissioner for Children.
Maxwell, G.M. and Carroll-Lind, J. (1996). Children's Experience of Violence. Wellington: Office of the Commissioner for Children.
Maxwell, G.M. and Morris, A. (1993). Families Victims and Culture: Youth Justice in New Zealand. Wellington: Institute of Criminology, Victoria University of Wellington and Social Policy Agency.
Maxwell, G.M. and Morris, A. (1996). Research on Family Group Conferences with Young Offenders. In: Hudson, J., Morris, A., Maxwell, G. & Galaway, B. Family Group Conferences: Perspectives on Policy and Practice. Annandale: The Federation Press.
Maxwell, G.M. and Morris, A. (1993). Families Victims and Culture: Youth Justice in New Zealand. Wellington: Institute of Criminology, Victoria University of Wellington and Social Policy Agency.
Maxwell, G.M. and Morris, A. (2000). Understanding Reoffending: Full report. Wellington: Institute of Criminology, Victoria University of Wellington.
McGeorge, P. (1995) Unpublished report to the Ministry of Health on services needed for children and adolescents.
Morris, A. and Maxwell, G. (1997) Family group conferences and convictions. Occasional paper No. 5. Wellington: Institute of Criminology, Victoria University of Wellington.
Morris, A. and Young, W. (1987) Juvenile justice in New Zealand: Policy and practice, Studies Series 1, Wellington: Institute of Criminology
Morris, A. Maxwell, G. and Shepherd, P. (1997a). Being a youth advocate: An analysis of their role and responsibilities. Wellington: Institute of Criminology for Victoria Link.
Potaka, L. (1997) Police views on the Children, Young Persons and Their Families Act 1989. Criminology: Aotearoa/New Zealand. No. 8; 6-7.
Shirley, I., Koopmnan-Boyden, P, Pool, I and St John, S. (1997) Family Change and Family Policies: New Zealand. In Kamerman, S. & Kahn, A., Family Change and Family Policies in Great Britain, Canada, New Zealand and the United States. Oxford: Clarendon.
Spier, P. (1997). Conviction and Sentencing of offenders in New Zealand: 1987 to 1996. Wellington: Ministry of Justice.
Werry, J.S. (1996). Mental health services for children and young people. Wellington: Ministry of Health.
Acknowledgments
This paper has been updated from one published by the Canadian Research Insititue for Law and the Family in the proceedings of "Youth Justice System Conference: An International Persepctive on Problems and Solutions"; Ottawa 1998. We would like to acknowledge the help of the New Zealand Police who have supplied data for this paper.
[1] Diversion can include a warning in writing or in the presence of the young person's parents, an apology to the victim, or the imposition of an additional sanction (for example, some community work)
[2] Youth aid officers making use of informal diversionary procedures are informed by the general principles of the Children Young Persons and Their Families Act 1989. Thus decisions are taken in consultation with victims and families.
[3] People in other jurisdictions often ask about whether or not there are certain cases for which family group conferences are not appropriate, for instance very serious offences. In New Zealand, all cases involving young offenders except murder and mansaughter will have a family group conference so that the views of families and victims can be heard. However, for those cases which go to the Youth Court, the judge can review the case and make a different disposition from that recommended if there are grounds for this. The Youth Court judge can refer the most serious offences on to the adults courts for sentence. The Youth Court will also decide the outcome when participants at the conference fail to agree. Cases of murder and manslaughter are dealt with in the adult courts.
[4] The orders in the Youth Court which are most frequently used include discharge without further order or penalty, reparation, community work, supervision with activity (includes a plan covering all acitivites for up to 6 months), supervision with residence (a residential programme for up to 3 months which can be followed by up to 6 months supervision) and transfer to the District Court for sentence (if over the age of 15 years).
[5] One example of the confusion that can exist about professional roles is provided in a recent analysis of the role of youth advocates (Morris et al, 1997).
[6] Almost all family group conferences result in agreed outcomes: the figure for 1996 was 86%. This has hardly changed over the years since the introduction of family group conferences. It is also unusual for Youth Court judges to disagree with the recommendations made to them from family group conferences.
[7] Although about a quarter of the young people said they did not know who had decided the outcome, the group most frequently identified by them as the decision-makers was their family. This was stated by about a third.
[8] The professionals alone were identified as the decision-makers by 15% of the families. These professionals seemed not to have accepted a redefined role for themselves: information providers and support givers rather than decision-makers. This could be resolved by better briefing of professionals about their roles and better training of them in the objectives of conferencing.
[9] These interviews sometimes took place soon after the family group conference but most of them occurred about two to three months later.
[10] There was a significant drop in the numbe rof young people appearing in courts between 1989 and 1990: from 8193 to 2352. Since then, there has been a gradual increase in the number of cases getting to court, but, even so, the 1996 figure of 3908 - the highest number since the Act was introduced - is still 64% less than in 1987.
[11] In 1997, Morris and Maxwell (1997a) produced a report on the role of youth advocates which sets out best practice guidelines and has formed the basis of a training programme for all youth advocates. It is hoped that best practice guidelines and training based on them will also be developed for youth justice coordinators and social workers but this has yet to occur.
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