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30 Whittier L. Rev. 645 (2008-2009)
Conceiving Injury - An Analysis of People v. Cross

handle is hein.journals/whitlr30 and id is 665 raw text is: CONCEIVING INJURY-AN ANALYSIS OF
PEOPLE V. CROSS
I. INTRODUCTION
The miracle of life! A bundle of joy! It's a boy! It's a girl! For
many couples, these phrases represent one of the happiest moments in a
woman's life: The onset of pregnancy, the determination of the baby's
sex, and the long awaited birth. But when a teen girl is sexually
assaulted by her stepfather and becomes pregnant, many would agree
her pregnancy does not represent a bundle of joy. Instead, her
pregnancy is a dismal reminder of a tainted childhood and brings forth
painful memories caused by one of the most traumatic forms of abuse
in modem society.
In May 2008, a study conducted by the American Academy of
Child and Adolescent Psychiatry indicated child sexual abuse was
reported up to 80,000 times [per] year.1 Further, one in four girls
and one in six boys are sexually abused before reaching eighteen years
of age.2 Studies suggest that of the 64,080 rapes that occurred between
2004 and 2005, 3,204 pregnancies could have resulted.3 The incidence
of pregnancy among rape and sexual assault victims demonstrates that
women and girls are not only victimized by their assailant upon their
initial attack, but due to their capacity to reproduce, their victimization
is ongoing when pregnancy results.    Fortunately, the California
Supreme Court addressed this distressing circumstance and provided a
1. Am. Acad. of Child & Adolescent Psych., Facts for Families: Child Sexual
Abuse [  1], http://www.aacap.org/cs/root/facts-for-families/childsexualabuse
(updated May 2008).
2. Darkness to  Light, Statistics Surrounding  Child  Sexual Abuse,
http://www.darkness2light.org/knowabout/statistics_2.asp (last accessed Mar. 3, 2009).
3. Rape, Abuse & Incest Nat]. Network, Who Are the Victims? Pregnancies
Resulting From Rape, http://www.rainn.org/get-information/statistics/sexual-assault-
victims (accessed Mar. 3, 2009).

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