Tracy and John had been married for seven years. They were so in love when they met at college. He brought her flowers and wanted to spend all of his free time with her. Everything was perfect. But it seemed to become increasingly tumultuous as soon as they got married, two years later. He didn't just want to spend all of his time with her; he had to know what she was doing every waking moment of the day. He had to approve of her activities and her friends. He called her at work every day. If she wasn't at her desk to answer the phone, she had to account for her whereabouts. He became very demanding of her when she was in his presence and yelled at her all the time. He hit her for the first time when she was pregnant with their son. She covered the bruises and told no one. She just couldn't believe the man that she loved and that was proud to have sired a son had actually beat her. That was four years ago. Now the way that he treats her is so regular, she no longer believes he is the same man she married. She finally got the courage to leave him. She filed for divorce and obtained a pro-thought that if she could just get away from him for good everything would be okay. They had split up before, but he had always come back, bearing gifts and veiled threats toward her or to take her son away. She hoped this time would be different because she had that protective order. But she knew he would be angry; she was very afraid. Her fear was warranted. He broke into the house, barricaded the door, and began to slap her around. Over the years, he had learned how to hit in places where there would be few or no marks. She scratched him on the arm. He told her that she wasn't going anywhere and that she would never leave him. In his rage, he screamed that everything in the house was his and he'd take it away if he wanted to. He grabbed her handbag and dumped the contents, stomping on them as they fell to the ground. He grabbed the scissors off the kitchen table and randomly started shredding things: her favorite armchair, some of her dresses from her closet. The police arrived. A neighbor who knew about her protective order had called them. The police took him away, but not before he told her, "I'll be back.... "
Zanita E. Fenton, Mirrored Silence: Reflections on Judicial Complicity in Private Violence, 78 Or. L. Rev. 995 (1999).