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Battered Women’s Syndrome
In 1991, Governor William Weld modified parole regulations and
permitted women to seek commutation if they could present evidence
indicating they suffered from battered women’s syndrome. A short while
later, the Governor, citing spousal abuse as his impetus, released
seven women convicted of killing their husbands, and the Great and
General Court of Massachusetts enacted Mass. Gen. L. ch. 233 23E
(1993), which permits the introduction of evidence of abuse in
criminal trials. These decisive acts brought the issue of domestic
abuse to the public’s attention and left many Massachusetts residents,
lawyers and judges struggling to define battered women’s syndrome. In
order to help these individuals define battered women’s syndrome, the
origins and development of the three primary theories of the syndrome
and recommended treatments are outlined below.
I. The Classical Theory of Battered Women’s Syndrome and its Origins
The Diagnostic and Statistical Manual of Mental Disorders
(DSM-IV), known in the mental health field as the clinician’s bible,
does not recognize battered women’s syndrome as a distinct mental
disorder. In fact, Dr. Lenore Walker, the architect of the classical
battered women’s syndrome theory, notes the syndrome is not an
illness, but a theory that draws upon the principles of learned
helplessness to explain why some women are unable to leave their
abusers. Therefore, the classical battered women’s syndrome theory is
best regarded as an offshoot of the theory of learned helplessness and
not a mental illness that afflicts abused women. The theory of learned
helplessness sought to account for the passive behavior subjects
exhibited when placed in an uncontrollable environment. In the late
60’s and early 70’s, Martin Seligman, a famous researcher in the field
of psychology, conducted a series of experiments in which dogs were
placed in one of two types of cages. In the former cage, henceforth
referred to as the shock cage, a bell would sound and the
experimenters would electrify the entire floor seconds later, shocking
the dog regardless of location. The latter cage, however, although
similar in every other respect to the shock cage, contained a small
area where the experimenters could administer no shock. Seligman
observed that while the dogs in the latter cage learned to run to the
nonelectrified area after a series of shocks, the dogs in the shock
cage gave up trying to escape, even when placed in the latter cage and
shown that escape was possible. Seligman theorized that the dogs’
initial experience in the uncontrollable shock cage led them to
believe that they could not control future events and was responsible
for the observed disruptions in behavior and learning. Thus, according
to the theory of learned helplessness, a subject placed in an
uncontrollable environment will become passive and accept painful
stimuli, even though escape is possible and apparent.


In the late 1970’s, Dr. Walker drew upon Seligman’s research
and incorporated it into her own theory, the battered women’s
syndrome, in an attempt to explain why battered women remain with
their abusers. According to Dr. Walker, battered women’s syndrome
contains two distinct elements: a cycle of violence and symptoms of
learned helplessness. The cycle of violence is composed of three
phases: the tension building phase, active battering phase and calm
loving respite phase. During the tension building phase, the victim is
subjected to verbal abuse and minor battering incidents, such as
slaps, pinches and psychological abuse. In this phase, the woman tries
to pacify her batterer by using techniques that have worked
previously. Typically, the woman showers her abuser with kindness or
attempts to avoid him. However, the victim’s attempts to pacify her
batter are often fruitless and only work to delay the inevitable acute
battering incident.

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The tension building phase ends and the active battering phase
begins when the verbal abuse and minor battering evolve into an acute
battering incident. A release of the tensions built during phase one
characterizes the active battering phase, which usually last for a
period of two to twenty-four hours. The violence during this phase is
unpredictable and inevitable, and statistics indicate that the risk of
the batterer murdering his victim is at its greatest. The batterer
places his victim in a constant state of fear, and she is unable to

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