Protection Order Use Among Latina Survivors of Intimate Partner Violence

678924 FCXXXX10.1177/1557085116678924Feminist CriminologyMessing et al. research-article2016 Article Feminist Criminology 2017, Vol. 12(3) 199–223 © The Author(s) 2016 Reprints and permissions: us.sagepub.com/en-us/journals-permissions DOI: 10.1177/1557085116678924 journals.sagepub.com/home/fcx Protection Order Use Among Latina Survivors of Intimate Partner Violence Jill Theresa Messing1, Sujey Vega2, and Alesha Durfee2 Abstract This mixed-methods study examines the impact of immigration status on the ability of Latina survivors of intimate partner violence (IPV) to file for and obtain a domestic violence protection order. Undocumented Latinas living in shelters are less likely to know what a protection order is or how to obtain one. At the same time, undocumented Latinas are more likely to believe that their partner would follow an order and that police would arrest their partner for a violation. Latina survivors of IPV live at the nexus of multiple systems of oppression; therefore, understanding their experiences using an intersectional framework is critically important. Keywords domestic violence, intimate partner violence, Latinas, immigration, protection orders, undocumented immigrants Nearly one third of U.S. women are physically assaulted by an intimate partner in their lifetime; for Hispanic women in the United States, this number is slightly higher at 37.1% (Black et al., 2011). Intimate partner violence (IPV)—which often consists of physical and sexual violence, emotional abuse, controlling behaviors, threats, and stalking—leads to physical injury as well as chronic health problems and mental health sequelae such as depression and posttraumatic stress disorder (Black et al., 2011; Bonomi, Holt, Martin, & Thompson, 2006; Campbell, 2002). In this article, we examine similarities and differences in access to protection orders among Latina survivors of IPV who are citizens or legal permanent residents of the United States and 1Arizona 2Arizona State University, Phoenix, AZ, USA State University, Tempe, AZ, USA Corresponding Author: Jill Theresa Messing, Associate Professor, School of Social Work, Arizona State University, 411 N. Central Ave., Suite 800, Phoenix, AZ 85004, USA. Email: Jill.Messing@asu.edu 200 Feminist Criminology 12(3) undocumented Latinas. Protection orders offer a unique opportunity to see how Latina survivors of IPV interface with and obtain assistance from both the criminal justice and civil legal systems. Although protection orders are obtained in the civil court, they are enforced through the criminal justice system. The criminal justice system in the United States often intervenes in IPV; in 2008, nearly 50% of IPV against women was reported to the police (Catalano, Smith, Snyder, & Rand, 2009). Latina women face substantial barriers to help-seeking, such as gender inequality and lack of trust in police (Messing, Becerra, Ward-Lasher, & Androff, 2015). Experiences of immigration and postmigration institutional and structural inequalities exacerbate vulnerabilities faced by Latina survivors of IPV and, at the same time, contribute to power and control exerted by abusive men (Erez, Adelman, & Gregory, 2009; Menjívar & Salcido, 2002; Raj & Silverman, 2002). Furthermore, when compared with nonimmigrant women, immigrant women report greater perceived risks and barriers to leaving an abusive relationship (Amanor-Boadu et al., 2012). Thus, it is more difficult for immigrant survivors of IPV to access social service and criminal justice resources intended to ameliorate the violence that they experience. In addition to the precarious position immigrant survivors find themselves in, Latinas who are legal residents, naturalized citizens, and/or U.S.-born citizens may face their own systemic barriers to accessing resources due to the “ripple effects” of anti-immigrant legislation (O’Leary & Sanchez, 2011). Moreover, because Latino families often exist in mixed-status households (where some members are undocumented whereas others are legal residents), it is important to include survivors who identify as undocumented immigrants, legal resident/citizens, and U.S.-born Latinas in research on help-seeking and to attend to the “collective decision making” of members of mixed-status households which “necessarily weights its interests in light of the conflicting interests of its individual members” (O’Leary & Sanchez, 2011, p. 117). Slightly more than 13% of the U.S. population is foreign-born (42.4 million people; Camarota & Zeigler, 2015). Latinos in the United States are a large and fast-growing group (Humes, Jones & Ramirez, 2011). Currently, approximately half of immigrants in the United States are women (American Immigration Council, 2014). The number of immigrant women is growing, leading some to indicate that migration is becoming feminized (Ezeala-Harrison, 2010; Hondagneu-Sotelo, 2001; Salcido & Menjivar, 2012). Previous research has examined immigrant survivors’ unique vulnerabilities and needs (Abraham, 2000; Erez & Hartley, 2003) and compared the experiences of immigrant and nonimmigrant women (Amanor-Boadu et al., 2012). To better understand Latinas’ experiences of help-seeking in the context of IPV, we use mixed methods to examine barriers to engagement in the civil justice system by making comparisons between resident/citizen and undocumented Latina survivors (survey methods, n = 195) and presenting thick description of those experiences (in-depth interviews, n = 27). Domestic Violence Protection Orders Domestic violence protection orders (also known as restraining orders) are civil orders intended to protect survivors by prohibiting or severely restricting contact between a Messing et al. 201 “petitioner” (a survivor) and a “respondent” (an abuser). Because they are civil orders, the survivor initiates the process, can file pro se (without legal representation), and can ask for a combination of provisions that best suits her specific needs. The provisions that can be requested by a petitioner vary dramatically between jurisdictions, but in general, orders can be used to force an abuser to vacate a shared residence, surrender weapons to police, limit or curtail visitation with or award custody of minor children, assign ownership of shared property (including a shared vehicle), award monetary compensation (including child and spousal support), and/or order counseling (DeJong & Burgess-Proctor, 2006; Eigenberg, McGuffee, Berry, & Hall, 2003). Eligibility for a protection order is based on a two-part test. First, the petitioner and respondent must have a “domestic” relationship. In many states, this means that they must be related by blood or marriage, have a romantic/dating relationship, have a child in common, or have shared a residence. Second, a judge or commissioner must generally rule that a “preponderance of the evidence” supports the petitioner’s claim that an act of domestic violence has occurred within a specified time frame or that the respondent will commit an act of domestic violence. The definition of what constitutes domestic violence varies by jurisdiction, but can include physical and sexual assault, as well as intimidation, stalking, and kidnapping. Estimates of the number of protection orders filed for and issued are difficult to obtain; however, Tjaden and Thoennes (2000) estimated that 20% of survivors who experience abuse file for a protection order, and that 1 million orders were issued to women each year in the mid-1990s. The number of orders is likely much higher now as the number of protection order filings between 1994 and 2004 increased by 35% (Schauffler, LaFountain, Kauder, & Strickland, 2006). Protection orders are available in all 50 states, the District of Columbia, U.S. Territories, and all tribal lands; furthermore, because of the full faith and credit provision in the Violence Against Women Act (VAWA; see also 18 U.S. Code § 2265), protection orders issued in one jurisdiction are valid and enforceable in all jurisdictions (DeJong & Burgess-Proctor, 2006; Eigenberg et al., 2003; Fleury-Steiner, Fleury-Steiner, & Miller, 2011). These civil orders are enforced through the criminal justice system, and in many states, violations of protection orders are subject to mandatory arrest laws (Hirschel, Buzawa, Pattavina, & Faggiani, 2007). Prior research indicates that protection orders are somewhat effective at preventing future abuse. Holt, Kernic, Lumley, Wolf, and Rivara (2002) found that those survivors who had obtained permanent protection orders were significantly less likely to report a subsequent physical assault to the police than were those survivors who either did not receive a protection order or those who had only obtained temporary orders (see also McFarlane et al., 2004). Carlson, Harris, and Holden (1999) found that only 23% of survivors who had obtained a protection order experienced a physical assault after receiving the order. Logan and Walker (2010), using a more expansive definition of reabuse that included property damage, threats to harm or kill, physical assault, and the use of a weapon, found that approximately 50% of women had their protection orders violated. Those women whose orders were violated, however, reported lower levels of violence in the 6 months after the issuance of the order as compared with the 202 Feminist Criminology 12(3) 6 months before the order. Furthermore, women had significantly lower levels of fear after the issuance of the order as compared with before. It is important to note that not all survivors benefit equally from protection orders—In the Carlson study, those women whose socioeconomic status was “very low” were more likely to be reabused than women of higher socioeconomic status. In addition, Mears, Carlson, Holden, and Harris (2001) found that non-White women living in low-income areas were more likely to be reabused than were other women. Ethnicity and Help-Seeking The role of ethnicity in help-seeking among women who are abused by an intimate partner is complex, with contextual, social, and emotional factors such as acculturation, social isolation, perceptions of family support, distrust of police, fears of deportation, language barriers, economic resources, employment, and the lack of culturally competent services complicating Latina women’s decision-making (Acevedo, 2000; Bauer et al., 2000; Erez et al., 2009; Lipsky, Caetano, Field, & Larkin, 2006; Menjívar & Salcido, 2002; Reina, Lohman, & Maldonado, 2014; Rizo & Macy, 2011; Sabina, Cuevas, & Schally, 2012). Overall, a meta-analysis of research on help-seeking among Latina women who experience IPV indicates that Latinas are less likely to use formal resources (such as social services, medical services, or law enforcement) than are nonLatina women (Rizo & Macy, 2011). Furthermore, immigrant Latinas (especially undocumented immigrant Latinas) are less likely to use formal resources than Latinas who are U.S. citizens (Ingram, 2007; Reina et al., 2014), as are Latinas who have low levels of acculturation (Lipsky et al., 2006). Latinas who reside in “linguistically isolated” areas are less likely to call the police than are other Latinas (Pearlman, Zierler, Gjelsvik, & Verhoek-Oftedahl, 2003). However, Latina women’s decision-making about protection orders may be different as compared with other forms of legal help-seeking. A study by Durfee and Messing (2012) indicated that Latinas filed for protection orders at rates similar to White women. Another study by Sabina et al. (2012) indicated that 11.2% of victimized Latinas had sought a protection order—socioeconomic status, acculturation, and permanent legal status were not significantly related to filing for a protection order. Finally, in a study by Krishnan, Hilbert, and VanLeeuwen (2001), Latinas were more likely to have sought a protection order (27%) than were non-Latinas (13%). This research extends previous inquiries by utilizing quantitative and qualitative methods to examine differences in protection order behavior, knowledge, and attitudes between Latinas who are legal permanent residents or citizens of the United States and Latinas who are undocumented. Method Sampling and Terminology Women in this study identified as Hispanic, Mexican, Cuban, Dominican, or Puerto Rican. Although each nationality experiences its presence in the United States Messing et al. 203 differently, we grouped these women into a collective Latina-identified label. This is due, in large part, to the way that all Spanish speakers and their descendants have been legislatively identified and treated in anti-immigrant legislation across the United States (Androff et al., 2011; Dowling & Inda, 2013; Magaña & Lee, 2013; Otto & de Bustamante, 2012; Quiroga, 2013; Rieser-Murphy & DeMarco, 2012). Antiimmigration laws in states such as Arizona (e.g., Senate Bill [SB] 1070) make it likely that physical features, language spoken, or any number of external identifiers might indicate a “reasonable suspicion” that the person is “unlawfully present” in the United States (SB 1070); indeed, a recent civil rights lawsuit in Arizona found that law enforcement officials had engaged in racial profiling (Ortega Melendres, et al. v. Arpaio, et al.). It is critical to recognize how a Latina-identified survivor’s precarious situation may be exacerbated by issues pertaining to immigration status such as fear of deportation (for herself or loved ones), language, race/ethnic discrimination, income inequality, and lack of social network (Erez, 2000; Erez et al., 2009; Menjívar & Salcido, 2002; Messing et al., 2015). We use the term “resident/citizen Latinas” to recognize the limits of a word like “documented,” which does not disaggregate among the spectrum of legal residency options. Similarly, a more complicated identifier than “undocumented” would recognize survivors who are in transition or have conditional residency during a VAWA application (Salcido, 2011). Unfortunately, in this study, additional information beyond a Latina survivor’s “undocumented” status was not collected. Thus, we grouped the resident/citizens into one category to recognize their more relatively stable position in the United States and placed undocumented survivors in another to account for their vulnerability in the justice system. Unlike other studies that have drawn their samples from survivors who are actively seeking protection orders (Gondolf, McWilliams, Hart, & Stuehling, 1994; Kaci, 1994; Klein, 1996; McFarlane et al., 2004; Richman, 2002; Zoellner et al., 2000) or have already received protection orders (Chaudhuri & Daly, 1992; Fischer & Rose, 1995; Keilitz, Hannaford, & Efkeman, 1997; Ptacek, 1999), we use a shelter-based sample. Although a shelter-based sample is not representative of all IPV survivors, there are two critical advantages to using a shelter-based sample as compared with other sampling strategies. First, a shelter-based sample includes survivors who have not filed for a protection order or who may not have had any contact with the civil legal or criminal justice systems. This is especially important when studying helpseeking among undocumented Latinas, who may be reticent to use the legal system as a resource. Second, all survivors in a shelter-based sample have demonstrated that they are willing to (a) access resources outside of their informal resource network and (b) separate from their abusive partner, each of which is necessary for survivors seeking orders. These are important methodological strengths as our research is able to examine legal mobilization among a population that is eligible and potentially willing to file for an order. In previous shelter-based research, approximately 30% to 40% of respondents reported ever having an order (Durfee & Messing, 2012; Logan, Walker, Jordan, & Leukefeld, 2006; Pennell, Burke, & Mulmat, 2002). 204 Feminist Criminology 12(3) Data Collection, Measurement, and Analysis Quantitative sample. Between 2012 and 2014, data were collected from women at 10 domestic violence shelters in a large metropolitan region of the Southwest United States. Although procedures varied slightly by shelter, surveys were generally distributed to shelter clients by staff or research assistants near the beginning of a survivor’s shelter stay. Of the 660 female, heterosexual IPV survivors who completed a survey, 195 (29.5%) self-identified as Latina. Two thirds of the Latina participants were recruited from two shelters. The survey instrument was translated and available in Spanish for women who preferred Spanish (45.1%). In this study, we focus on participants’ self-reported demographic and relationship characteristics (including documentation status) and protection order behavior, knowledge, and attitudes. Survivors were asked whether they knew what a protection order was before coming to shelter and whether they had tried to obtain one. Women were also asked whether they thought that their partner would follow an order and whether they believed that the police would arrest their partner for a violation of the order. Women who had tried to obtain an order were additionally asked whether they were successful in obtaining one, whether their partner contested it, whether they found it helpful, and whether they currently had an order. For women who had not tried to obtain an order, they were asked whether they knew where to obtain an order, thought an order would be helpful, were concerned that an order would increase the violence that they faced, and were afraid to obtain a protection order. Chi-square analyses were used to examine the association between Latina women’s protection order behaviors, attitudes and beliefs, and their documentation status. Qualitative sample. In 2013, 100 domestic violence survivors residing in one of nine participating shelters were interviewed. These survivors were recruited both from flyers and by word of mouth, and were given a US$20 gift card for their participation. The interviews were semistructured and contained 25 main questions about legal help-seeking, interactions with court personnel, and protection orders (including beliefs about, knowledge about, sources of information about, attempts to obtain, impacts of obtaining/not obtaining an order, and enforcement of protection orders). Of the 100 survivors interviewed, 27 identified as Latina. The interviews with these 27 survivors ranged in length from 29 to 100 min, with a mean of 42.65 min. Survivors were given the option of having the interview conducted in Spanish or English; as is shown in Table 1, 11 interviews were conducted in Spanish and 16 were conducted in English. All interviews were audio-recorded and transcribed in the language they were conducted in. The Spanish language interviews were then translated into English and cross-checked. All interviewees were encouraged to use pseudonyms to protect their confidentiality and safety; as an additional precaution, all interviews were de-identified after they were transcribed and (if applicable) translated. Moreover, all names in this study are pseudonyms randomly chosen by the researchers so as to provide another layer of anonymity to the women who participated in this study. Each interview was coded for themes by two members of the research team. 205 Messing et al. Table 1. Survivor and Abuser Demographic and Relationship Characteristics, and Comparison Between Survey Sample (n = 195) and Interview Sample (n = 27). Variable Survivor age Survivor race/ethnicity Survivor citizenship status Abuser race/ethnicity Abuser citizenship status Language of survey/ interview Current relationship status Children under 18 (includes current pregnancy) Education Victim currently employed Victim employed before entering shelter Currently has POa Category of variable Years Latina Multiracial U.S. citizen/legal permanent resident Other Missing Latino White Black/African American Native American Missing/Other U.S. citizen/legal permanent resident Other Missing Spanish English Boyfriend/ex-boyfriend Husband Ex-husband/separated/ estranged Missing Yes, has children under 18 No, does not have children under 18 Missing Number of children under 18 Yes, the abuser is the biological father of at least one child Less than a high school degree High school graduate/GED Some college, college degree, or more Missing No Yes Missing No Yes Missing No Yes Missing Survey sample n (%) M (SD) Interview sample n (%) M (SD) 33.9 (9.4) 159 (81.5%) 36 (18.5%) 104 (53.3%) 31.7 (8.7) 26 (96.3%) 1 (3.7%) 15 (55.6%) 82 (42.1%) 9 (4.8%) 137 (70.3%) 34 (17.4%) 10 (5.1%) 1 (0.5%) 13 (6.6%) 151 (77.4%) 12 (44.4%) — 19 (70.4%) 4 (14.8%) 3 (11.1%) 1 (3.7%) — 17 (63%) 38 (19.5%) 6 (3.1%) 88 (45.1%) 107 (54.9%) 79 (40.5%) 72 (36.9%) 36 (18.5%) 10 (37%) — 16 (59.3%) 11 (40.7%) 15 (55.6%) 6 (22.2%) 5 (18.5%) 8 (4.1%) 160 (82.1%) 34 (17.4%) 1 (3.7%) 25 (88.9%) 2 (11.1%) 1 (0.5%) 2.5 (1.6) 119 (61.0%) — 2.3 (1.7) 24 (95.8%) 77 (39.5%) 42 (21.5%) 64 (32.8%) 12 (44.4%) 7 (25.9%) 8 (29.6%) 12 (6.2%) 152 (77.9%) 41 (21.0%) 2 (1.0%) 142 (72.8%) 51 (26.2%) 2 (1.0%) 17 (27.4) 39 (62.9) 6 (9.7) — 24 (88.9%) 3 (11.1%) — 13 (48.2%) 14 (57.1%) — 20 (74.1%) 6 (23.1%) 1 (3.7%) Note. GED = general educational development; PO = protection order. aIn the survey sample, this is limited to women who applied for a PO prior to going to shelter (n = 62). 206 Feminist Criminology 12(3) Results Sample Characteristics Quantitative sample. Among surveyed women who identified as Latina (n = 159) or multiracial including Latina (n = 36), slightly more than half (53.3%) were citizens or residents of the United States (see Table 1); among resident/citizen Latinas, 74.0% reported being born in the United States. Nearly one third of resident/citizen Latinas identified as multiracial, whereas only one undocumented woman identified as multiracial (χ2 = 98.23, p < .001; see Table 2). Undocumented Latinas (82.9%) were significantly more likely than resident/citizen Latinas (10.6%) to respond to the survey in Spanish (χ2 = 32.09, p < .001). Undocumented Latinas (22.7%) were significantly less likely than resident/citizen Latinas (43.4%) to have attended any college (χ2 = 9.01, p < .05), though there were no differences in employment status among resident/citizen and undocumented Latinas with 21.6% of surveyed Latinas holding employment while in shelter and 26.2% reporting employment prior to entering shelter (see Table 2). The abusive partners of undocumented Latinas were significantly more likely to be Latino (80.5% vs. 59.6%; χ2 = 8.24, p < .05) and undocumented (34.6% vs. 7.9%; χ2 = 20.12, p < .001). Furthermore, undocumented Latinas were significantly more likely than resident/citizen Latinas to be currently or formerly married to their abuser (χ2 = 28.41, p < .001) and to have a child in common with him (χ2 = 13.32, p < .001). Nearly half (46.8%) of undocumented Latinas were currently married to their abusive partner, and 82.9% had a child with their abuser, compared with 29.7% and 56.3% of resident/citizen Latinas, respectively. Qualitative sample. Of the 27 survivors interviewed, 26 (96.3%, n = 26) exclusively identified as Latina, and one (3.7%) identified as multiracial (see Table 1). Fifteen of the interviewed survivors reported that they were resident/citizens, and 12 women reported that they were undocumented. The majority of women’s abusive partners were Latino (70.4%, n = 19), followed by White (14.8%, n = 4), Black (11.1%, n = 3), and Native American (3.7%, n = 1). The survivors were, on average, younger (31.7 years) than their abusers (34.3 years), were less likely to be U.S. citizens or legal permanent residents (55.6%, n = 15) than their abusers (63.0%, n = 17), and were more likely to be undocumented (44.4%, n = 12) than their abusers (37.0%, n = 10). The majority of the interviewed survivors had relationship ties with their abusers that could make legal help-seeking more complicated and would make a complete separation from their abusers hard to achieve. Almost all of the survivors (85.2%, n = 23) had at least one child under the age of 18, and nearly all of the abusers were the biological parent of at least one child under the age of 18 (96.0%, n = 24, missing data for 3). On average, the survivors had 2.3 children under the age of 18. Six were still married to their abusers (22.2%), five (18.5%) were formerly married to their abuser, and 15 (55.6%) were the girlfriends or former girlfriends of their abusers. 207 Messing et al. Table 2. Survivor and Abuser Demographic and Relationship Characteristics, and Comparison Between Resident/Citizen (n = 104) and Undocumented (n = 82) Latinas. Variable Survivor age Survivor race/ ethnicitya,b Abuser race/ethnicitya Abuser citizenship statusa Language of surveya Current relationship statusa Children under 18 (includes current pregnancy) Educationa Survivor currently employed Survivor employed before shelter Category of variable Years Latina Multiracial Latino White Other Missing Resident/citizen Undocumented Spanish English Boyfriend/ex-boyfriend Husband Ex-husband/separated/ estranged Yes, has children under 18 No, does not have children under 18 Number of children under 18 Yes, the abuser is the biological father of at least one childa Less than a high school degree High school graduate/ GED Some college, college degree, or more No Yes No Yes Resident/citizen Latinas n (%) M (SD) Undocumented Latinas n (%) M (SD) 33.7 (10.1) 68 (65.4%) 36 (34.6%) 62 (59.6%) 23 (22.1%) 16 (15.4%) 3 (2.9%) 93 (92.1%) 8 (7.9%) 11 (10.6%) 93 (89.4%) 61 (60.4%) 30 (29.7%) 10 (9.9%) 34.1 (8.8) 81 (98.8%) 1 (1.2%) 66 (80.5%) 11 (13.4%) 5 (6.1%) — 53 (65.4%) 28 (34.6%) 68 (82.9%) 14 (17.1%) 17 (22.1%) 36 (46.8%) 24 (31.2%) 84 (80.8%) 68 (84.0%) 20 (19.2%) 13 (16.0%) 2.4 (1.7) 2.5 (1.6) 49 (56.3%) 63 (82.9%) 34 (34.3%) 40 (53.3%) 22 (22.2%) 18 (24.0%) 43 (43.4%) 7 (22.7%) 85 (83.3%) 17 (16.7%) 77 (74.8%) 26 (25.2%) 60 (73.2%) 22 (26.8%) 58 (71.6%) 23 (28.4%) Note. GED = general educational development. aSignificant differences (χ2) between resident/citizen and undocumented Latinas. bFisher’s exact test was used due to an expected cell size of less than five. 208 Feminist Criminology 12(3) As for economic self-sufficiency, only three of the 27 interviewees (11.1%) were currently employed. Prior to entering shelter, however, 14 (51.9%) had been employed. Almost half (44.4%, n = 12) of the women did not have a high school degree, seven (25.9%) had a high school degree or general educational development (GED), and eight (29.6%) had some college, a college degree, or additional education beyond a college degree. Finally, six of the 27 Latinas currently had a protection order (22.2%), and eight had ever had a protection order (29.6%). Knowledge and Beliefs About Protection Orders In the survey, there were no differences in the proportion of resident/citizen and undocumented Latinas who tried to obtain a protection order (28.2% and 33.3%, respectively; see Table 3). Resident/citizen Latinas were significantly more likely (χ2 = 14.89, p < .001) to know what a protection order was prior to coming to shelter. However, undocumented Latinas were nearly 3 times more likely than resident/ citizen Latinas (57.3% vs. 21.8%, respectively) to believe that a protection order would be followed by their intimate partner (χ2 = 24.69, p < .001). Out of 27 Latinaidentified qualitative interviews, 11 survivors felt that their abusive partner would follow the protection order. Primarily, they reported that their abuser would fear being involved with the criminal justice system (“he is fearful of the police” and “he doesn’t want to go back to jail”). Of these 11 women, eight had partners who were undocumented immigrants and thus more vulnerable to arrest, detainment, and deportation by Immigration and Customs Enforcement than resident/citizen partners. Angelica was a citizen of the United States, but her abuser was not. In discussing whether or not her abuser would likely abide by the protection order, Angelica noted, He ain’t trying to—if they catch him [law enforcement] is hard on that right now, on the immigration laws right now. He’s not gonna do it. If he tries to, he’s not gonna—[law enforcement] gonna collect him right away, and take his butt back. You know what I mean. He’s not—it’s a no-win situation for him. It’s a no-win situation, so he needs to abide by it no matter what really, in all due reality. Although Angelica did not express support for restrictive immigration policies, she did sense that her abuser’s undocumented status would factor in his willingness to abide by the order. Indeed, Flor, who was herself undocumented, stated, “He knew, he—it wasn’t a possibility but more so a fact that if he touched me he would be deported.” When asked to elaborate how she knew that her abuser “knew” this, Flor responded with “He told me.” Both undocumented and resident/ citizen Latinas who felt an abuser would follow the protection order expressed that the consequences of not doing so were a deterrent. Latinas expressed that undocumented abusers were far more frightened of an arrest triggering deportation proceedings and that this compounded severity made them more likely to avoid violating a protection order. 209 Messing et al. Table 3. Knowledge and Attitudes About Protection Orders Among Resident/Citizen (n = 104) and Undocumented (n = 82) Latinas. Variable Before coming to shelter, did you know what an OP was?a Do you believe your partner would follow an OP?a Do you believe that police would arrest your partner for violating an OP?a Had you ever tried to get an OP against your partner? Resident/citizen Latinas n (%) Undocumented Latinas n (%) No Yes 16 (15.7) 86 (84.3) 33 (41.3) 47 (58.7) No Yes Unsure No Yes Unsure 39 (38.6) 22 (21.8) 40 (39.6) 25 (25.0) 46 (46.0) 29 (29.0) 15 (18.3) 47 (57.3) 20 (24.4) 10 (12.2) 59 (72.0) 13 (15.8) No Yes 74 (71.8) 29 (28.2) 54 (66.7) 27 (33.3) Category of variable Note. Data are missing for two to four participants per analysis. OP = order of protection. aSignificant (p < .05) bivariate (χ2) differences between resident/citizen and undocumented Latinas. In the survey sample, there were significant differences in undocumented and resident/ citizen Latinas’ belief that that police would arrest their partner for a protection order violation (χ2 = 12.48, p < .01), with 72% of undocumented Latinas believing that the police would arrest their partner for a violation of the order (vs. 46% of resident/citizen Latinas). Similarly, in the qualitative data, undocumented Latinas were more likely to express confidence that a police officer would come to aid her if the abuser violated a protection order. For instance, when asked what a protection order can do for her, Fabiola (an undocumented female) responded confidently, “Well, for me it is practical because I can call the police at whatever time that he does, or wants to do something to me or even gets near me and I can call the police.” When asked what would happen if her abuser violated the order, Fabiola explained, “They would have arrested him because he is, he is not respecting an order of protection and even more because it is authorized by a judge.” Some undocumented women referenced previous positive experiences with police in their interviews and expressed confidence that police would respond to a protection order violation (“he would be arrested”) or indicated that they trusted the police to respond “because every time that I have called always, always they have helped me.” These undocumented women expressed that police had behaved “very well,” were “very friendly,” and/or were “helpful” in the past; therefore, they trusted future police intervention. However, other undocumented women feared their own and their abuser’s deportation and, thus, did not reach out for legal assistance. For instance, Socorro, an undocumented Latina, held tremendous fears about calling the police. Her abuser and those close to him exacerbated those fears, telling Socorro that the police would not help her: 210 Feminist Criminology 12(3) It’s been said and people say that the police don’t listen, well because we are not from here and one doesn’t have financial means and umm . . . and . . . And well because we are illegal here, well they don’t pay much attention to us . . . they don’t give you the help you need when you need it. Or they ask like for . . . requisites that you can’t provide them with. And more than anything they, people close to [abuser] would tell me I shouldn’t call them, that it wasn’t an option to call the police, because the police cause harm. When Socorro called the police, they told her “there is nothing we could do” because her abusive partner had fled the scene. On her third call to police, “the officer [finally] told me . . . I had to get a protection order.” Socorro was persistent and realized that the police were not going to deport her or call Child Protective Services to take her children away as her abuser had threatened. Women’s prior experience with police was important to their willingness to utilize the criminal justice system as a resource. Undocumented survivors who had positive interactions with police, even when they were not provided with adequate assistance or information, noted a willingness to utilize the justice system. For instance, Lourdes admitted having a “fear that they will, well given your situation, that they will deport you.” However, when police were called, Lourdes remembered, “the police took a long time to arrive, he [abuser] was able to leave . . . but ah, one who spoke Spanish arrived, he behaved very well, with me, well in that way he helped me.” This helpful behavior can be read against a preconceived fear that the police might be rude, mean, or seek to deport survivors. For Lourdes, even though police “took a long time,” thus allowing her abuser to flee, she reconciled that with her opinion that they were helpful and called for a Spanish-speaking officer to communicate with her. In contrast, undocumented and resident/citizen Latina women who had negative encounters with police in the past were skeptical about future positive interactions. In general, Latinas believed that police would respond to a call for assistance; however, a concern was how the police would respond. Both undocumented and resident/citizen Latinas revealed that, in the past, police had not listened to them, had dismissed them, or showed preferential treatment to the abuser. Rosy, a resident/citizen Latina, expressed her extreme mistrust toward police because of the way they had handled her case in the past: “I attempted 2 times before to call the police, and the 2 times he would call the police back and say that it was all by mistake.” According to Rosy, the police believed her abuser and never came to her assistance. Despite this, Rosy was persistent in calling the police as she had few options for help. Rosy recalled that, during a party, he was choking me, and I called the police. They came into the house. They even saw that there was blood. It wasn’t my blood, but they saw blood. They didn’t even investigate . . . they ask[ed] me in front of him what was going on. Of course I was gonna say there was nothing going on. The fourth time Rosy called the police it was to tell them that her abuser was drunk and banging on her windows from the outside. When police arrived, they told him, “You need to leave and when you’re sober you can come back.” Although Rosy finally fled 211 Messing et al. Table 4. Experiences of Women Who Tried to Obtain a PO Before Entering Shelter Among Resident/Citizen (n = 29) and Undocumented (n = 27) Latinas. Variable Were you successful in obtaining the PO? Did your partner contest the PO? Do you currently have a PO? Did you find the PO to be helpful?a Category of variable Resident/citizen Latinas n (%) Undocumented Latinas n (%) No Yes No Yes No Yes No Yes 8 (28.6) 20 (71.4) 17 (65.4) 9 (34.6) 10 (37.0) 17 (63.0) 14 (56.0) 11 (44.0) 5 (20.0) 20 (80.0) 10 (45.5) 12 (54.5) 7 (34.0) 16 (69.6) 2 (9.5) 19 (90.5) Note. Data are missing for three to 10 participants per analysis. PO = protection order. her abuser and secured a protection order against him, these initial interactions with police led to mistrust. When asked whether she believed police would respond if her abuser violated the order, Rosy casually remarked, “I’m sure they would respond. I’m sure they would come, but they would be—I mean it wouldn’t—it would be too late.” One undocumented Latina remembered clearly how the officer who responded to her call said, “well, the majority of time you’re going to go back to him, but if you want to leave, you should leave now.” The police officer provided information about shelter, but his response lacked empathy. Some women noted the “attitude” that police had with them, particularly when they had called the police repeatedly, and questioned whether police had an ambition to protect them or were resentful of the call for assistance. Both undocumented and resident/citizen Latinas shared examples of police officers who seemed bothered by their call or who took so long to arrive that the abuser fled. Frustrated by response times, Laura pleaded in her interview that police come faster. You’ll never know if someone’s in danger—their life’s in danger. If you take your time and just come to it like nothing’s wrong, something might happen before you get there . . . when someone says their life’s been threatened, they should take it seriously. Both undocumented and resident/citizen Latinas who had negative encounters with police in the past expressed doubt that future responses would be adequate. Among survivors who had tried to obtain a protection order (n = 56; see Table 4), there were no differences between resident/citizen and undocumented Latina survivors’ reports of being able to successfully obtain a protection order (with 75.5% of women being successful overall), whether their partner contested the order (with 43.8% of partners contesting the order), and whether they currently had a protection order (with 66.0% of women currently having an order). However, undocumented 212 Feminist Criminology 12(3) Latinas were significantly more likely to find the order to be helpful (χ2 = 10.87, p < .001). Among undocumented Latinas, almost all (90.5%) of them found the order to be helpful, whereas less than half (44.0%) of resident/citizen Latinas reported that the order was helpful. Undocumented Latinas in the qualitative interviews were also likely to express a favorable opinion of protection orders, with 92% (12 out of 13) of undocumented Latinas mentioning how protection orders provided safety for survivors as well as their children. Undocumented Latinas expressed relief that they had access to a mechanism that made them feel protected, secure, safe, and better prepared to handle future interactions with their abuser. For Patricia, the distance that the protection order afforded gave her the opportunity to resist her abuser’s overtures, “emotionally, physically, no calls, no letter . . . And right now I’m like I’m done, I’m done. I’m done. I don’t want you now . . . So the day I speak to him, I am emotionally well.” This “emotional” benefit of having a protection order was critical for Patricia to muster the strength to assert “I’m done, I’m done. I’m done.” Undocumented Latinas also voiced feelings of validation. Clara related the importance of a protection order as means of feeling heard: “Well I felt . . . stronger . . . more confident in myself, that someone was paying attention to me . . . what I felt was that someone . . . heard me.” For undocumented Latina survivors, social networks are often tied to their abuser’s family or friends, leaving them without informal sources of support. Lourdes revealed that, with an order of protection, now other people will be helpful . . . I didn’t even want to go out (whispers)—I was scared. But now this . . . they made me copies [of PO] so that I can go into the school, to see my sister, see my daughter and well, I could now go out feeling much more calm. Lourdes had sisters in the area, and the protection order allowed her to visit them without feeling anxious that her abuser would show up. She had a paper that represented “power that one has that, uh, protects you.” Claiming this power, and taking power away from an abusive partner, was important for undocumented Latinas who otherwise found themselves powerless in an abusive relationship within a country where they felt that they had limited rights. The protection order provided them with options, documentation, and a clear path for recourse if further abused. Consistent with their confidence in police intervention, undocumented Latinas expressed relief that they could call the police when their abuser was near. For Concepcion, knowing that the police would believe her due to the protection order made her feel better: “Well if you have one and he tries to do something, you can quickly call the police, and that is, like your proof that he is not a good person toward you.” As previously noted, some undocumented Latinas indicated the importance of the protection order being an official document, handed down by a judge, identifying their abuser, and justifying their right to feel safe from their abuser. The protection order validated women’s experiences and placed the law and the police on their side. Although Mariana had not obtained a protection order, the fear of it was enough to keep her abuser under control: “right now he only gets near me [to see our daughter] because he’s scared when I’m in [shelter]. He thinks I have the police 100% on my 213 Messing et al. Table 5. Reasons That Women Chose Not to Seek an OP Before Entering Shelter Among Resident/Citizen (n = 74) and Undocumented (n = 54) Latinas. Variable Did you know where to obtain an OP?a Did you think an OP would be helpful for you?a Did you think that an OP may increase the violence from your partner? Were you afraid to obtain an OP?a Category of variable Resident/citizen Latinas n (%) Undocumented Latinas n (%) No Yes No Yes No Yes 22 (33.3) 44 (66.7) 38 (54.3) 32 (45.7) 31 (49.2) 32 (50.8) 33 (63.5) 19 (36.5) 11 (21.2) 41 (78.8) 18 (37.5) 30 (62.5) No Yes 36 (58.1) 26 (41.9) 16 (30.8) 36 (69.2) Note. Data are missing for six to 17 participants per analysis. OP = order of protection. aSignificant (p < .05) bivariate (χ2) differences between resident/citizen and undocumented Latinas. side because I am in this place.” Mariana’s residence in the shelter indicated to her abuser that she had official protection; she was glad to have him think that she had access to police intervention if needed. Among Latinas who did not obtain a protection order, approximately the same proportion of resident/citizen (50.8%) and undocumented (62.5%) Latina survivors thought that the order would increase the violence that they faced from their partner (see Table 5). In the qualitative interviews, a higher percentage of resident/citizen Latinas (compared with undocumented Latinas; 64.29% and 23.07%, respectively) felt a protection order would upset their abusive partner and that it would not be protective at the moment of escalated violence. Resident/citizen Latinas had greater doubts about prompt and adequate police response; they also doubted the ability of a protection order to keep them safe from an abuser who intended to harm them for obtaining one. Stephanie described how a protection order would make her abuser angry that she had attempted to take his power away, “and now he wants to take control, and I think it builds anger on that. It makes them worse.” Other resident/citizen Latinas feared that their abuser’s anger at being ordered to stay away would make him more determined to seek her out; if the abuser did seek to harm the survivor, the protection order would not be a deterrent. As one resident/citizen Latina proclaimed, “Whaddya gonna do? Throw it at them?” Latina resident/citizens expressed that the protection order “was just a paper” and would do nothing to protect them from abuse. They expressed that it was not worth angering their abuser and potentially risk being killed because “it takes so long ’til the police comes when you call them.” Thus, the “paper” would provoke their abuser and the police would not be able to protect them. As another resident/citizen survivor related, “they’re not gonna work unless you have a cop outside of your house.” Some undocumented Latinas shared this view; for 214 Feminist Criminology 12(3) example, Louisa reiterated this theme by recognizing that the protection order “It’s just a paper, they’re not gonna be scared of a paper.” Significantly more undocumented Latinas thought that an order would be helpful (χ2 = 13.63, p < .001), but they were significantly less likely to know where to obtain an order (χ2 = 10.61, p < .01) and were significantly more likely to report being afraid to obtain one (χ2 = 8.49, p < .01). Some undocumented Latinas in the qualitative interviews revealed fearing accessing a protection order because of their immigration status. One undocumented survivor explained, “we are denied help a lot” because of immigration status. This had led her to assume that both shelter and protection orders were unavailable to her. For another undocumented Latina, Ana Lisa, her abuser’s threats about her immigration status raised questions about whether she could trust the police. Ana Lisa recalled one moment when I got really frustrated and I felt very humiliated and I called the police and again he started to tell me, don’t call them because you don’t, you don’t have papers and you’re undocumented and I’m going to call them. These threats by Ana Lisa’s abuser led her to believe that she may be putting herself in danger as an undocumented immigrant by seeking assistance. Both women revealed how shelter staff helped them understand that their undocumented status did not preclude them from seeking safety or an order of protection. In addition to believing that they were ineligible for aid due to their immigration status, undocumented Latinas in the qualitative interviews were more likely to resist getting a protection order due to the prohibition on contact between the petitioner and the respondent, which effectively precludes any type of relationship between them (Goodmark, 2012). The decision not to seek a protection order was often explained by a desire to maintain father/child relationships and being economically dependent on an abusive partner. Alejandra, for instance, explained that it took several visits from police to convince her to leave her relationship: The first 2 times it was out of fear or that insecurity of mine [voice cracking], because of my status, because I depended on him, like I had . . . like very much in my head—that it would harm me instead of helping me. More than anything because of my kids. Beyond fears of aggravating abuse (“it would provoke [the abuser]”), that “a paper” would not protect them, lack of police response (“[they] never did anything”), and reluctance to sever ties with their children’s father and/or extended family, Latina survivors noted additional reasons for avoiding the court system. For some, going to court presented difficult logistical issues: they had to take time off of work, find child care and transportation, and avoid their abusive partner during the trek. Other survivors were dissuaded by the potential of reliving trauma and of having to tell and retell traumatic events without guarantee that they would be believed. Amira, an undocumented survivor, was concerned about how her children would fare in the proceedings and whether the judge would be willing to include them in the order: Messing et al. 215 “Sometimes [the judge] only gives [the order] to the victim and doesn’t give it to the kids. Because they are his biological children, you get me.” The possibility of being required to provide her abuser access to minor children was enough to dissuade her from going to court. Similarly, resident/citizen survivors indicated wanting to “move on” as a reason for not invoking the court system. Elizabeth related her concerns about being re-traumatized during the process of obtaininga protection order: “Will I have to tell everything, and it will be documented? Having to go through all that is—I don’t think that it’s helping me move on.” Other survivors were worried that having a protection order would require them to avoid the abuser and mutual friends or family: “that means sometime you gotta not tell your family. You gotta not tell certain people about the situation.” Another resident/citizen Latina was concerned that the protection order would keep her tethered to her abuser: “I really just wanna just run away and just keep moving forward, just get out of there. Try to have them forget about me.” For undocumented and resident/citizen Latinas who had the means to leave and were not economically or socially dependent on their abuser, the option to sever ties and not “kick up dust” presented a more viable answer for their situation than going through “the hassle” of a protection order. Because the stress affiliated with getting a protection order outweighed the benefits, these survivors found other means of avoidance and protecting themselves. Discussion In this study, approximately 30% of Latinas had tried to obtain a protection order; this is at the low end of estimates (30%-40%) in previous, more diverse shelter-based samples (Durfee & Messing, 2012; Logan et al., 2006; Pennell et al., 2002). Protection orders can be a source of safety and empowerment for survivors, but some Latinas expressed reservations about whether an order would work, police response times, and their involvement with a criminal justice system that they did not trust. Formal system utilization, particularly the use of protection orders, which place survivors in direct contact with the criminal justice system, may not be a preferred method of intervention for survivors who see involvement with the criminal justice system as prolonging their abuse (Raj & Silverman, 2002; Sokoloff & Pearce, 2011). Undocumented Latinas or those who have had negative experiences with the police may be reluctant to obtain an order for various reasons. However, undocumented Latinas in this study were more likely to believe that law enforcement would respond to a violation of the protection order. Previous research has found that trust in the police is more important than fear of deportation in Latinas’ willingness to report violent crime victimization (Messing et al, 2015). This is consistent with the qualitative findings in this study that undocumented women were often scared to call the police at first, but, if they had a positive interaction with police, they were likely to indicate increased trust in their future response. However, survivors who had negative interactions with police were not confident that they would be of assistance and, thus, were less likely to believe that an order of protection could help them. Previous 216 Feminist Criminology 12(3) research has demonstrated that survivors who are satisfied with police response were more likely to call for assistance in the future (Fleury-Steiner, Bybee, Sullivan, Belknap, & Melton, 2006). Taking an intersectional lens clarifies that conventional methods of aiding survivors of IPV may result in problematic relationships with state agencies and law enforcement. For Latinas with undocumented partners, mistrust of the system is a double-edged sword. Undocumented abusers were frightened that an arrest could trigger deportation proceedings, making them less likely to violate a protection order and increasing survivor perceived safety. However, this was a deterrent to getting an order because women did not want deportation proceedings triggered as a result of a protection order that they obtained (“I don’t wanna be the person to do that to him”). Some resistance to obtaining an order arose from economic dependence, family cohesiveness, or isolation from relationships outside of their abuser and his social network. Indeed, some undocumented Latinas lack social networks and must rely on their abuser for support (Erez et al., 2009). Although there may not be institutional barriers to obtaining an order of protection for undocumented survivors, orders of protection may nonetheless operate differently for survivors and abusers who worry about immigration status and/or economic stability on top of personal safety. Throughout the nation, police agencies have been taxed with immigration enforcement leading to mistrust and fear of police. Cecilia Menjívar (2013) described immigrants living with “legal violence” or the structural and symbolic violence enacted by legislation that results in the “suffering and pain, through exploitation, exclusion and discriminatory practices” toward immigrant communities (p. 234). Whether Latinas are resident/citizens, undocumented, or in mixed-status situations (families where some members are resident/citizens and others are undocumented), they live in a present fear of police involvement, especially in jurisdictions that are known to take discriminatory law enforcement actions against anyone fitting a particular racial/ethnic profile. Although some Latina survivors expressed that legal violence dissuaded abusers from violating a protection order, it is critical to recognize how the presence of fear is imlicit, even in a situation where survivors feel empowered by their abuser’s fear of the police. For some undocumented survivors, a fear of legal violence led to hesitance to call the police. When a survivor is scared of violence from the abuser as well as legal violence from the state, she may fear police as agents of deportation and not of protection; indeed, abusers often use this fear to stop survivors from calling for help (Reina et al., 2014; Salcido & Adelman, 2004; Vidales, 2010). Some survivors expressed gratitude toward police who presented as kind and helpful, especially if they were willing to help despite language barriers. However, survivors were often pleasantly surprised by police whom they expected to be part of the system of legal violence that they feared (Menjívar, 2013), a fear often stoked by an abusive partner as a form of abuse and intimidation. As these survivors were interviewed in shelter, they may be unique in their willingness to engage with formal intervention systems, including the legal system. There may be more women who were too scared to engage police or formal service intervention, and continue to endure violence from their partners because of fears of violence from the Messing et al. 217 state, or do not seek shelter because they fear seeking assistance or mistrust police intervention due to previous negative encounters. What is clear is how fears surrounding immigration can exacerbate their feelings of vulnerability at the hands of both the state and their abuser (Erez et al., 2009; Reina et al., 2014; Salcido, 2011). For undocumented women, the process of migrating to a new country under clandestine methods can result in seclusion, isolation, and lack of trust for people in their surroundings. This isolation is intensified if an undocumented Latina lacks a social/ familial support network in the receiving community (Menjívar, 2000). Women who recently migrated may also be taken advantage of due to their precarious situations, leading to distrust of strangers and increased dependency on abusers (Menjívar, 2000; Zavella, 2011). Undocumented Latinas may feel linguistically and culturally disadvantaged (Reina et al., 2014). The relative isolation from friends or family combined with feeling ill prepared to engage with the surrounding environment might lead to resistance in engaging with formal services including obtaining a protection order. Undocumented Latinas reported being more afraid of obtaining an order of protection, but resident/citizen Latinas indicated that their partners were more likely to commit violence due to the order. The qualitative interviews suggest that the fear that undocumented women are referencing is a fear of the state due to their documentation status and not a fear of their abuser. Further evidence for this interpretation in this study is that undocumented women were often afraid to call the police due to abuse unless they had previously had a positive interaction with police; in this case, they were likely to use the criminal justice system as a resource. Although resident/citizen Latinas may not experience the legal violence of dealing with the immigration system, there remains a potential for them to equally distrust police intervention given previous exposure to discriminatory or insensitive practices by law enforcement. In the study, we sought to simultaneously address how immigration status may make a difference in a survivor’s relationship to the criminal justice system and their willingness to file and obtain a protection order; however, we are also conscious that resident/citizen Latinas experience their own vectors of oppression tied to immigration status and ethnicity. Mixed-status family situations where an abuser, children, or other family members are undocumented may play a role in the way that resident–citizen Latinas interact with police. In addition, prior negative encounters with the criminal justice system and experience with police officers who are dismissive or insensitive to either themselves or their community both cast doubt on the helpfulness of future police interventions. Even as both resident/citizen and undocumented Latinas reported doubts about the way that police would handle their cases, qualitative interviews revealed a dependency on police for safety from an abuser. Regardless of whether they had a protection order, survivors in this study expressed that they were likely to call the police in a future altercation with their abuser. Strengths and Limitations This study has several limitations. First, data were collected from women in domestic violence shelters in a single metropolitan city in the Southwest United States. Thus, 218 Feminist Criminology 12(3) women in this study are not representative of all IPV survivors and may be particularly different from survivors who do not seek a social service intervention for IPV. Due to the limited number of Latina survivors who completed surveys and our desire in this analysis to examine differences between resident/citizen and undocumented Latinas, we used a series of bivariate analyses (as opposed to a multivariate model), which increases the likelihood of Type I error. We did not ask women who participated in the qualitative interviews and identified as citizens whether they were born in the United States. Future research should gather more details about immigration status, including the participant’s status at the time of the abuse and at the time of data collection. This research focuses on Latina women, and future research should also expand to examine the experience of additional immigrant groups (including refugees) with IPV, orders of protection, and police response. The strengths of this research study outweigh the limitations. First, we examine Latina IPV survivors decisions not to obtain an order of protection; previous research has primarily examined the experiences of women who have obtained an order, making this research unique. Utilizing mixed methods, we are able to both look at trends across Latina women’s experiences with quantitative data and contextualize those experiences using qualitative data. Finally, comparisons of resident/citizen and undocumented women’s experiences provide important information about differential use of the civil and criminal justice systems based on immigration status. Implications This research has implications for both policy and practice. Resident/citizen Latinas were more likely to know what an order of protection was before entering shelter, indicating a need for greater outreach and education within immigrant communities about what an order of protection is, the various uses of an order, and how to obtain one. A protection order can assist women in accessing additional formal resource networks; this is of particular importance for immigrant women who may not have knowledge of available services both within and outside of the criminal justice system (Ingram, 2007; Lipsky et al., 2006; Reina et al., 2014). Women are often dependent upon their abusive partners for economic resources, and this may deter women from reporting abuse to the police. Undocumented women, in particular, face oppressive, violent, and discriminatory work environments (Eggerth, DeLaney, Flynn & Jacobson, 2012; Waugh, 2010). Policies that enhance women’s economic self-sufficiency and end oppression, discrimination, and harassment in the workplace will assist all women in becoming and remaining violence-free. Consistent with previous research (e.g., Menjívar & Bejarano, 2010), women in this study reported that positive interactions with police officers were instrumental in their choice to further access criminal and civil justice resources. Some police officers are not knowledgeable about the power and control dynamics of IPV, and may respond in ways that are not perceived as helpful by survivors (Ward-Lasher, Messing & Hart, 2017). Given the importance of positive police interaction, there is a need for police officer training that includes education about coercive control and homicide risk, as well as information about the fair and equitable treatment of all victims of crime. It is Messing et al. 219 expected that education and training about IPV would increase officers’ understanding of the difficulties of leaving an abusive partner and encourage empathic listening and responsiveness to survivor needs. Orders of protection may be helpful for some women and may increase violence, risk, and fear for others. IPV practitioners should use an evidence-based practice model where they provide a survivor with the best evidence available about risk and effective interventions, use their own expertise to make suggestions, and then allow a survivor the space to make a determination about what she feels is best in her particular situation (Messing & Thaller, 2015). Policies should ensure that practice is survivor-centered and takes into account women’s self-determination. Practical assistance, such as child care and transportation, will make orders of protection accessible for women who choose to obtain them. IPV is a complex issue, and survivors often have competing priorities, for example, love for their partner and safety for themselves and their children (Glass et al., 2010). These competing priorities may be both different (need for safety from an abusive partner vs. a fear of immigration detention) and particularly salient for women with marginalized identities, including Latina women, undocumented women, and women in mixed-status families. 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As a social worker, Dr. Messing is committed to evidence-based practice and is, thus, concerned with the development and testing of innovative interventions for survivors of intimate partner violence. Sujey Vega is an assistant professor of Women and Gender Studies at Arizona State University. Her research explores belonging and the way Latina/os make their own notions of home in the United States. She is currently exploring the growth and role of female Latinas in the Church of Jesus Christ of Latter Day Saints. Alesha Durfee is an associate professor and graduate director in Women and Gender Studies at Arizona State University. Her research and teaching focus on social policy and domestic violence using quantitative and qualitative methods. Her current research includes legal mobilization and the use of protection orders by domestic violence survivors, the effects of mandatory arrest policies, the social construction of domestic violence victimization, and how gender influences the interpretation of survivors’ narratives of violence by the justice system.