The Journal of The DuPage County Bar Association

Back Issues > Vol. 20 (2007-08)

Problems for Females in the Juvenile Justice System: What is Happening and What Can Be Done?
by Chantelle Jackson and Mark A. Perlaky

On March 30th, 2008, April Cooper, Cara Murphy, Britney Mayes, Brittini Hardcastle, Kayla Hassell, and Mercades Nichols all took part in a vicious attack on a 16-year-old high school cheerleader named Victoria Lindsay.1 The attack was so vicious and brutal that Lindsay was left with a concussion, swelling, and a loss of hearing and vision on her left side.2 All of the girls who committed the attack, along with two boys who stood guard as the attack occurred, were arrested and formally charged with felony battery and false imprisonment,3 and officials say that a kidnapping charge is also a possibility, since Lindsay was forced into a car and taken to South Lakeland, Florida, after the attack.4

The attack might have otherwise gone largely unnoticed by the mainstream media, except that the girls posted a video of the attack on YouTube,5 a website where individual users may upload clips of videos that they have created for basically any user in the world to see.6 Almost instantly, viewers of the video posted responses to it, and parents and police involved in the case were quick to blame YouTube and MySpace7, the social networking site where the girls traded insults and messages leading up to and orchestrating the attack.8 The Polk County Sheriff, Grady Judd, called the attack "animalistic behavior," and stated that "It’s incumbent on YouTube and MySpace to make drastic changes. If we desensitize kids to this kind of beating today, what’s next?"9

It is a certainly reasonable and expected reaction to condemn such acts of violence as these girls have committed, and it is likely even reasonable to view with audacity the supposed arrogance of these teens by publicly posting video of the attack online. Naturally, Sheriff Judd called for the girls to be tried as adults for the beating, and stiff bail was set for each girl as well.10 However, as some have pointed out, this attack is not the first of its kind, and almost certainly won’t be the last.11 Instead, it is evidence of a continually growing problem of violent crimes committed by teen girls who will inevitably end up in a juvenile justice system that seldom meets their needs.

In the late 1990s and early 2000s, a number of commentators attempted to shed light on certain growing problems involving females in the juvenile justice system.12 Although the arguments and conclusions of these commentators differed sig-nificantly, common themes about girls in the juvenile justice system emerged. These themes included the fact that, traditionally, juvenile girls have primarily been arrested for status offenses, such as running away from home and curfew violations.13 However, another theme is that the growing general agreement about a continuing upward trend towards violent crimes committed by females,14 and that much female delinquent behavior can be directly traced to histories of physical and sexual abuse.15 Commentators also seem to agree that when they are introduced to the juvenile justice system, girls’ needs in response to these issues are seldom met.16

Since the various commentators have brought these growing problems to light, one would hope that some improvements would have been made causing statistical instances of female juvenile delinquency to decline. Sadly, statistics show that incidents of female juvenile delinquency from 1996 to 2002 have continued a near-steady increase nationwide.17 In particular, crimes against persons, drug offenses, and offenses against public order by females have become much more frequent in that time span, tripling in number over a nearly 20-year time period.18 These increases stand in direct contrast to boys’ statistics, which definitively show higher numbers of boy delinquents than girl delinquents, but also show a definite decrease in overall delinquency from 1996 to 2002, with only offenses against public order increasing in frequency in that time.19

So what is Illinois’ contribution to these statistics? Does Illinois follow the national trends regarding female arrests and delinquency? On the one hand, one might presume that Illinois’s statistics would mimic the national numbers, particularly considering that the state houses the third largest metropolitan area in the nation as of the last U.S. Census.20 On the other hand, one could also reasonably believe that Illinois would exhibit a downward trend in overall female juvenile crime, considering that it offers protections for juveniles such as statutorily mandating the presence of a parent or legal guardian in court,21 establishing a comprehensive Probation Department22 and mandating that they prepare a investigative social history report about respondent minors prior to sentencing.23 Further, Illinois offers juveniles orders of protection against harmful individuals,24 and is one of only three states that mandate counsel for juveniles.25

These statutory provisions suggest a concerted attempt by the state to meet the needs of all juvenile delinquents, and might suggest a diminished number of juvenile offenders. Despite these efforts, however, a compilation of recent Illinois data confirms that female juvenile delinquent crime is on the rise. In 2003, the total number of female juvenile arrests in Illinois was around 9594.26 In 2004, the number jumped to 10,078,27 and in 2005, the number rose again to 10,258.28 The number of arrests was, of course, higher in counties within or immediately surrounding the Chicagoland area, with Cook County having the highest arrest rate for each year,29 closely followed by Winnebago County, Kane County, DuPage and Lake Counties.30 Not surprisingly, McHenry and Will Counties also reported a higher-than-usual number of female juvenile arrests for those years compared to the rest of the counties in the state.31

An increase of only 664 arrests of juvenile females between 2003 and 2005 probably does not initially sound very alarming. Additionally, the fact that arrest rates for female delinquents are higher in well-populated areas is unlikely to surprise many people. What should be troubling, however, is the rise in certain types of crimes being committed. Without question, the highest numbers of juvenile female arrests from 2003 until 2005 were for violent offenses,32 confirming statements of commentators describing this trend.33 Unsurprisingly, violent offense arrest numbers also followed the state statistical trend by rising in each of those years from 3709 to 3932 between 2003 and 2004,34 topping out at 4039 in 2005.35 As a method of comparison, Property Offenses, the next-highest number of offenses committed by juvenile delinquent females each year, fluctuated between 3531 in 2003,36 3432 in 2004,37 and 3436 in 2005.38

Also somewhat alarming has been the total increase in drug offenses by female juveniles over that time period. In 2003, the total number of drug-related arrests for juvenile females stood at 537,39 but rose to 573 in 200440 and rose again to 641 in 2005.41 In fact, among the counties in the Chicagoland area reporting higher-than-usual rates of female juvenile delinquency,42 only McHenry County saw a consistent drop in female drug-related arrests each year between 2003 and 2005.43 On the other hand, Cook, DuPage, and Lake Counties all saw increases in such arrests, and DuPage County essentially doubled its female drug arrest rate between 2003 and 2005.44 What should be even more alarming to DuPage County is the unique fact that drug offenses were the only category of female juvenile arrests that rose consistently in that time period.45

An increase in violent crime and drug use by juvenile females seems likely to be a combustible mixture that will continue to augment for years to come. As increased arrests appear to have done nothing to decrease female juvenile crime numbers, it is likely that further increased arrests will have no substantial effect on decreasing those numbers. The obvious resultant question is what, if anything, can be done to stem this rising tide of female juvenile delinquency? Blaming our culture for becoming increasingly violent and hedonistic, or YouTube and MySpace for allowing teens to communicate threatening messages to one another, is far too simple and seldom effective. A deeper, albeit brief understanding of the various problems that female delinquents face is needed again in order to effectuate more lasting solutions.

National statistics show that there is a definite connection between a juvenile’s family life and instances of juvenile crime. A study by the Office of Juvenile Justice and Delinquency Prevention has shown that juveniles living with both biological parents reported lower instances of gang involvement, drug use, theft, running away from home, vandalism, and assault with intent to seriously injure.46 Additionally, the study found that the most closely-related factor to law-violating behavior was gang involvement by the juvenile personally or by having friends or family members involved in gangs.47 This offers clear evidence that a proper familial support system is necessary to keep any juvenile, and especially female juveniles, away from criminal activity. What must be implemented or changed to offer these support systems for girls, however, is an extremely difficult question.

Improving support systems will be problematic precisely because quite often, the support systems themselves are causing harm to girls. It is generally agreed that many, if not most, female juvenile offenders enter the system from family histories involving abuse, neglect, and other instances of domestic violence.48 Around seventy percent of girls in the juvenile justice system have histories of physical and/or sexual abuse, and many girls have reported suffering injuries due to childhood punishment.49 One study has specifically linked sexually abused girls with tendencies toward violent behavior,50 and often, sexual abuse goes unreported, keeping anyone from stepping in to improve matters before they get to extreme levels.51 Girls in need of stable support systems thus often find them completely out of reach.

It seems clear that our society must find a way of dealing with families to offer less problematic living situations for girls. However, until that potentially far-off day is reached, a comprehensive approach is needed for dealing with juvenile delinquent girls who enter the system. This must start with gender-specific approaches to understanding and modifying juvenile girl behavior.52 This includes acknowledging that female behavior will be different from male behavior, especially when expressing anti-social, violent, or other rebellious tendencies.53 This behavior will undoubtedly be influenced by aforementioned abusive relationships that girls experience54 and counseling to help them recover from these experiences will need to be as available as possible.55 Available counseling is all the more important when considering that generally, mental health problems exist in much higher rates among juvenile delinquent girls than among boys: a somewhat recent study has estimated that eighty-four percent of girls kept in juvenile justice facilities needed some sort of mental health treatment, compared with around twenty-seven percent of boys.56

In this regard, it must be noted that the quantity and quality of programs and services for juvenile delinquent girls are still likely at unacceptable levels. Author Meda Chesney-Lind, in her article "Are Girls Closing the Gender Gap in Violence?" has reported that a 1993 study conducted by the National Organization of Women’s San Francisco chapter found that "only 8.7 percent of the programs funded by the major [San Francisco] organization funding children and youth programs ‘specifically addressed the needs of girls…’"57 Chesney-Lind also notes that a number of people working in the juvenile justice system express a particular preference for working with boys rather than girls, often reporting that girls are much more "manipulative" and "hysterical," while boys are reported as "honest," "open," and "less complex."58 These reports suggest that increased funding is definitely needed for programs specifically directed at females in the juvenile justice system, as are workers who are specifically trained to meet girls’ specific emotional behaviors and needs.59

In terms of the legal process itself, attorneys, judges, and a jurisdiction’s Probation Department should be mindful of their role in aiding juvenile delinquent females. To begin, it cannot be understated that juvenile females should have counsel present at all court proceedings, something that becomes increasingly important when considering the sensitive and particularized issues facing many juvenile girls. Fortunately, Illinois mandates this by statute,60 but, as previously mentioned, many states still do not.61 Additionally, judges and attorneys should continue their duty to work toward a juvenile girl’s best interests, paying close attention to the severity of the crime or crimes alleged, the background and social history of the girl, the potential for harm that could result from placement of the girl at home or in juvenile detention, and what potential services could aid the girl in the rehabilitation process.

All courtroom participants should also be mindful to avoid unnecessary gender biases in the process. While it is true that a gender-biased assessment of a girl’s best interests can be helpful in terms of meeting the particularized needs of juvenile girls,62 unnecessary gender biases are obviously unhelpful. These can include unnecessarily downplaying the seriousness of a crime or situation because it is not traditionally committed or suffered by girls, brushing off girls’ reactions to crimes or home situations as the results of oversensitivity or developing emotions, and otherwise treating girls as unknowledgeable about their situations solely because of their gender. Further, attorneys for juvenile girls should remain vigilant, understanding their role in maintaining as normal an attorney-client relationship as possible,63 and always doing whatever is necessary to protect their clients’ best interests.

There is simply not enough time or space in any article to detail all of the problems facing juvenile girls in the juvenile justice system. However, it is clear that problems for juvenile delinquent girls are not going away, and crimes committed by juvenile females continue to rise, particularly in violent crimes and drug use. It can summarily be said that better support systems for juvenile girls are needed, and this includes recognizing and repairing abusive situations in which juvenile delinquent girls often find themselves. Further, the entire juvenile justice system needs to continue increasing its understanding of the particular emotional needs of girls coming into the system, and to increase the services provided where possible. Finally, the attorneys, judges, and probation officers involved in the process must each fulfill their ethical and legal duties and obligations when considering juvenile girls who come before them. Improving the experiences for females in the juvenile justice system may appear to be a monumental task requiring cooperation from many different people in many different departments, but a concerted effort by juvenile justice system workers today could save juvenile girls a lot of trouble tomorrow.

1 8 Teens Charged in Taped Beating, Tampabay.com, April 8, 2008, http://www.tampabay.com/incoming/article448619.ece.

2 Id.

3 Damien Cave, Eight Teenagers Charged in Internet Beating Have Their Day on the Web, N.Y. Times, April 12, 2008, at A11

4 8 Teens Charged in Taped Beating, Tampabay.com, April 8, 2008, http://www.tampabay.com/incoming/article448619.ece.

5 http://www.youtube.com

6 See Company History, YouTube.com, available at: http://youtube.com/t/about (last visited April 16, 2008). Although the unedited video has since been taken down on YouTube, the girls’ attack can still be seen on YouTube via clips of various news shows discussing it. See e.g., Glen Beck, 6 Cheerleaders beat up girlfriend cnn [sic], YouTube.com, available at: http://youtube.com/watch?v=4eluN_rIa4w (last visited April 16, 2008)

7 http://www.myspace.com

8 See Damien Cave, Eight Teenagers Charged in Internet Beating Have Their Day on the Web, N.Y. Times, April 12, 2008, at A11. The parents of Victoria Lindsay have been particularly outspoken against the two websites, with the father, Patrick Lindsay, stating "As far as I’m concerned, MySpace is the Antichrist for children," and the mother, Talisa Lindsay, noting that "this MySpace…this YouTube has gone too far." Id.

9 8 Teens Charged in Taped Beating, Tampabay.com, April 8, 2008, http://www.tampabay.com/incoming/article448619.ece.

10 Id.

11 See Damien Cave, Eight Teenagers Charged in Internet Beating Have Their Day on the Web, N.Y. Times, April 12, 2008, at A11.

12 See e.g., Nadine Lanctot and Marc Le Blanc, Explaining Deviance by Adolescent Females, 29 Crime & Just. 113 (2002) (examining patterns of female delinquent behavior and studying data derived from these examinations); Anne Bowen Poulin, Female Delinquents: Defining Their Place in the Justice System, 1996 Wis. L. Rev. 541 (1996) (examining the place of females in the juvenile justice system and advocating improvement in rehabilitative services for girls entering the system); Marty Beyer et. al., A Better Way to Spend $500,000: How the Juvenile Justice System Fails Girls, 18 Wis. Women’s L.J. 51 (Spring 2003) (articulating the failures and difficulties involved in the placement of girls in juvenile detention facilities) [hereinafter A Better Way]; Joseph R. Biden, Jr., What About the Girls: The Role of the Federal Government in Addressing the Rise in Female Juvenile Offenders, 14 Stan. L. & Pol’y Rev. 29 (2003) (studying the statistical and background data on females in the juvenile justice system and arguing for greater federal funding for juvenile justice programs) [hereinafter What About Girls?].

13 See Robert E. Shepherd, Jr., Girls in the Juvenile Justice System, 15 Crim. Just. 44 (Winter 2001) (Stating that in 1999, girls accounted for 59 percent of runaway arrests and 30 percent of curfew violations); Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 31 (confirming similar statistical rates for status offenses in 2000).

14 See Meda Chesney-Lind, Are Girls Closing the Gender Gap in Violence?, 16 Crim. Just. 18, 19 (Spring 2001) (stating that arrests of girls for serious violent offenses increased 64.3 percent between 1989 and 1998); Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 32 (stating that female violent crime was 103% above the rate it was for juvenile girls in 1981). But see Lucille R. DiPietro, Female Juvenile Delinquents: The Emergence of Women as Criminal Offenders and Their Place in the Juvenile Justice System, 2 Ann. 2000 ATLA CLE 1789 (July 2000) (stating that violent crimes for juvenile females were still statistically below those of juvenile delinquent boys).

15 See Marty Beyer et. al, A Better Way, supra n. 12 at 52 (stating that around 70% of females in the juvenile justice system have been victims of prior sexual abuse, and at one Philadelphia Youth Center, 81% of girls experienced physical or sexual abuse); Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 36 (Stating that 70% of females in the system have been victims of sexual abuse, compared to 20% of the general population).

16 See, e.g., Katherine Hunt Federle, The Institutionalization of Female Delinquency, 48 Buff. L. Rev. 881, 900 (Fall 2000) (Criticizing the juvenile court as an institution for its failure to respond to the problems of juvenile delinquent girls); See generally Marty Beyer, et. al, A Better Way, 18 Wis. Women’s L.J. 51 (Spring 2003) (articulating the failures and difficulties involved in the placement of girls in juvenile detention facilities); Anne Bowen Poulin, Female Delinquents: Defining Their Place in the Justice System, 1996 Wis. L. Rev. 541 (1996) (examining the place of females in the juvenile justice system and advocating improvement in rehabilitative services for girls entering the system).

17 Office of Juvenile Justice and Delinquency Prevention, Juvenile Offenders and Victims: 2006 National Report at 161, available at http://ojjdp.ncjrs.gov/ojstatbb/nr2006/downloads/chapter6.xls (last visited April 7, 2008). Crimes against persons committed by females jumped from 94,988 in 1996 to 102,561 in 1997, and the number stood at 109,670 in 2002. Id. Drug offenses among females jumped from 26,506 in 1996 to 35,115 in 2002, while offenses against public order rose from 82,727 to 113,825 in that time period. Id.

18 Id.

19 Id.

20 United States Census Bureau, Table 3b. Population in Metropolitan and Micropolitan Statistical Areas Ranked Separately by 2000 Population for the United States in Puerto Rico: 1990 and 2000, available at http://www.census.gov/population/cen2000/phc-t29/tab03b.xls. Chicago, IL is ranked only behind the New York, New York and Los Angeles, California metropolitan areas in total population as of April 1, 2000. Id.

21 705 ILCS 405/5-110

22 705 ILCS 405/6-1

23 705 ILCS 405/5-701

24 705 ILCS 405/1-16

25 705 ILCS 405/5-170; See Center for Policy Alternatives, "Juvenile Waiver of Counsel," available at http://www.stateaction.org/issues/issue.cfm/
issue/JuvenileWaiver.xml (last visited April 7, 2008) (the other states are Iowa and Texas).

26 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003 (On file with author).

27 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2004 (On file with author). Further alarming is the fact that of those arrests, 3014 females were in secure detention as a result. Illinois Criminal Justice Information Authority, Table 31: Number of Youth Admissions to Secure Detention by Sex, 2004 (On file with author).

28 Illinois Criminal Justice Information Authority, Number of Juvenile Arrests by Gender, Offense Category and County for Calendar Year 2005. The rate for Illinois is at least higher than one of its neighbor states as in 2006, Iowa reported 10,105 instances of female arrests. Iowa Division of Criminal and Juvenile Justice Planning, Juvenile Delinquency Annual Statistical Report: Allegation Types and Subtypes, May 2007, available at: http://www.state.ia.us/government/dhr/cjjp/images/pdf/Annual%202006%20Statewide%20Report.pdf. However, in stark contrast stands Wisconsin, which reported 35,748 female juvenile arrests in 2006. Wisconsin Office of Juvenile Assistance, Crime and Arrests in Wisconsin: Statewide Juvenile Arrests by Sex-2006, December 2007, available at: http://www.wi-doc.com/index_juvenile.htm.

29 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003 (On file with author); Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Gender, Offense Category and County for Calendar Year 2004 (On file with author); Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Gender, Offense Category and County for Calendar Year 2005 (On file with author).

30 Id. From 2003-2005, Cook and Winnebago Counties were first and second statistically in total number of female juvenile arrests, while Kane, DuPage, and Lake Counties alternated between the third and fifth spots for all three years. Id.

31 Id.

32 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003 (On file with author); Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2004 (On file with author); Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2005 (On file with author).

33 See Meda Chesney-Lind, Are Girls Closing the Gender Gap in Violence?, supra note 14 at 19; Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 32.

34 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003 (On file with author); Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2004 (On file with author).

35 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2005 (On file with author).

36 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003 (On file with author).

37 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2004 (On file with author).

38 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2005 (On file with author).

39 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003 (On file with author).

40 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2004 (On file with author).

41 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2005 (On file with author).

42 The author speaks of Cook, DuPage, Kane, Lake, Winnebago, Will, and McHenry counties. See supra p. 3.

43 Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2003; Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2004; Illinois Criminal Justice Information Authority, Number of Juvenile Female Arrests by Offense Category and County for Calendar Year 2005 (On file with author).

44 Id.

45 Id.

46 Office of Juvenile Justice and Delinquency Prevention, Juvenile Offenders and Victims: 2006 National Report, ch. 3 at 72, available at: http://ojjdp.ncjrs.gov/ojstatbb/nr2006/downloads/chapter3.pdf.

47 Id.

48 Lucille R. DiPietro, Female Juvenile Delinquents: The Emergence of Women as Criminal Offenders and Their Place in the Juvenile Justice System, 2. Ann.2000 ATLA CLE 1789 (2000).

49 Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 36.

50 Meda Chesney-Lind, Are Girls Closing the Gender Gap in Violence?, supra n. 14 at 20

51 Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 37.

52 See Anne Bowen Poulin, Female Delinquents: Defining Their Place in the Justice System, supra n. 14 at 556-58; Robert E. Shepherd, Jr., Girls in the Juvenile Justice System, supra n. 13 at 44-45.

53 Anne Bowen Poulin, Female Delinquents: Defining Their Place in the Justice System, supra n. 14 at 557.

54 See supra notes 47-50.

55 See Marty Beyer et. al, A Better Way, supra n. 12 at 71.

56 Joseph R. Biden, Jr., What About Girls?, supra n. 12 at 38.

57 Meda Chesney-Lind, Are Girls Closing the Gender Gap in Violence?, supra n. 14 at 23

58 Id.

59 For a glimpse of how bad a differentiation in conditions between girls and boys can be at a juvenile detention facility, see D.B. v. Tewksbury, 545 F. Supp. 896 (D. C. Or. 1982)

60 705 ILCS 405/5-170

61 See Center for Policy Alternatives, "Juvenile Waiver of Counsel," available at http://www.stateaction.org/
issues/issue.cfm/issue/JuvenileWaiver.xml.

62 Anne Bowen Poulin, Female Delinquents: Defining Their Place in the Justice System, supra n. 14 at 568.

63 See ABA Model Rules of Professional Conduct R. 1.14 and Comment.

Chantelle Jackson is a graduate of The Ohio State University (2003) and graduated from DePaul University College of Law (2006).  Chantelle was admitted to practice in 2006. Chantelle is currently an associate at A. Traub and Associates.  Practicing all areas of family law, real estate, and estate planning.  Chantelle is a former supervisor of the DuPage County Public Defender’s Office Juvenile Division where she concentrated her practice on representing juveniles on criminal matters and representing parents and children on abuse, neglect, and dependency matters.

Mark Perlaky is a 2008 Graduate of Northern Illinois University College of Law in Dekalb, Illinois and 2008 Ohio Bar candidate. He is a 2004 graduate of the University of Toledo in Toledo, Ohio. He recently served as a research and 711 intern at the DuPage Public Defender’s Office and was a student representative for Thomson-West. Mark has served as the Lead Articles Editor for the Northern Illinois University Law Review, and has published a number of articles including An Illinois Court’s Response to the “Day of Silence”, DuPage County Bar Association Brief (January 2008).


 
 
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