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Stalking: Consultation Paper (html)

  • Posted on July 14, 2021

1. Nature and dynamics of stalking

Introduction

1.1 Stalking is often a terrifying crime. People who are stalked can feel constantly unsafe, anxious and vulnerable. Whether it involves physical violence or not, stalking can cause significant fear and distress.

1.2 While the phenomenon of stalking has existed for many years, it has only been recognised as a crime relatively recently. For that reason it is not always well-understood, either by the people experiencing stalking or the system that is meant to respond to it. Victim survivors and system operators can be unsure how to stop the stalking and start the recovery process.

1.3 Stalking has been recognised in the family violence context. The Royal Commission into Family Violence made recommendations to develop a comprehensive family violence system. Stalking by partners or former partners falls within this specialist system, which has processes in place to assess the risk posed to victims, hold people who stalk to account and plan for victim safety and recovery.

1.4 The death of Celeste Manno in November 2020 shows that the non-family violence stalking system also needs significant reform and led to this Victorian Law Reform Commission reference. This consultation paper does not discuss the details of Ms Manno’s death because it is currently before the courts. But the non-family violence stalking system is the focus of this consultation paper.

What is stalking?

1.5 Stalking is defined in law. It has also been defined by psychiatrists in clinical settings, and forensic psychologists and criminologists in academic research. Stalking can include:

• Surveillance: a person who stalks may obsessively monitor the person they are stalking. They may follow the person they are stalking, track them using technology, or loiter around their home or workplace.[2]

• Repetition: a person who stalks contacts the person they are stalking multiple times. Stalking can happen over the course of one day, for a few weeks, or many years.[3]

• Degradation: a person who stalks may verbally abuse the person they are stalking, post denigrating comments or images online about them,[4] or humiliate them in public.

• Intrusion: the person who stalks repeatedly approaches the person they are stalking, interferes with their property, or enters their home or workplace.[5] Stalking involves making ‘one’s presence felt where it would not otherwise exist’.[6]

1.6 Stalking can involve violence towards the person being stalked or damage to their property.

1.7 Not all stalking results in physical violence. Stalking can involve actions that would, in another context, be legal or even welcome. For example, gift-giving is usually legal. But if someone repeatedly gives another person unwanted gifts and will not stop when asked, this can be stalking.[7] Even though it can involve seemingly everyday behaviour, it feels intrusive and can induce distress and fear.[8]

Example: escalation with threats of violence[9]

A man obsessively threatened, harassed and stalked a woman who would not date him. The man had known his victim for over a year and had been stalking her for almost the entire duration, causing her to move house multiple times and change her routine.

He repeatedly followed her home and on one occasion he assaulted her, causing injury. He also gave her gifts and made declarations of love.

He became increasingly aggressive, taking her phone and searching her texts, and telling her ‘I’m going to rape you and I’m going to kill you’.

After she moved house a further time, the man’s threats escalated when he couldn’t find her. Police arrested the man. At his bail application, he continued to maintain the delusion that the woman was his partner.

1.8 Stalking can involve using (and misusing) legal and/or complaints processes (such as complaining to the Ombudsman) to maintain access to the person being stalked. This can result in a person being endlessly tied to the person who is stalking them.

1.9 As evidenced in other jurisdictions, stalking may also be facilitated by licensed private investigators.[10] Victoria has a statutory scheme for licensing private investigators.[11] We are interested to understand if and how these services are used in the context of non-family violence stalking.

1.10 Stalking is illegal. In Victoria, it is a criminal offence with a maximum penalty of ten years imprisonment. In Victorian legislation, a course of conduct constituting stalking is two or more acts or one single protracted act. Section 21A of the Crimes Act 1958 contains an extensive, but non-exhaustive, list of behaviours defining stalking. These include:

• following the person being stalked

• contacting the person being stalked by any means

• publishing material about or purporting to originate from the person being stalked

• tracking the person being stalked

• making threats

• keeping the person being stalked under surveillance

• technology-facilitated abuse.

1.11 Stalking can be grounds for an intervention order under the Personal Safety Intervention Orders Act 2010 (Vic) (PSIO Act).[12] Despite these laws, stalking can entrap victim survivors in a cycle of abuse that is difficult to identify, prove, and remove themselves from.

1.12 Because stalking has such a wide definition, these laws have been criticised as potentially capturing behaviour that is not ‘true’ stalking, drawing more people into the criminal justice system for relatively low-level offending.[13]

Measuring the prevalence of stalking: who is stalked, how and why?

1.13 Anyone can experience stalking regardless of gender, race, sexuality, disability or socioeconomic status. However, stalking is a gendered crime, disproportionately perpetrated by men against women. Such gendered violence is enabled by the unequal structures of society.[14]

1.14 It is difficult to measure how common stalking is. New technology has led to new ways of stalking, making it even harder to measure.[15] However, the most recent statistics from the Crime Statistics Agency reveal a significant upward trend over the last 24 months for the offence of stalking.[16]

1.15 The most recent statistics indicate 13,872 stalking offences were recorded by police in Victoria. This includes:

• family violence stalking

• non-family violence stalking.[17]

1.16 Stalking in the context of family violence is reported at a slightly higher rate than non-family violence stalking.[18]

1.17 Fewer personal safety order applications were finalised in the Magistrates’ Court of Victoria in 2018–2019 compared to previous years.[19]

1.18 The following statistics demonstrate the available prevalence rates for stalking:[20]

• From the age of 15, 17 per cent of women and 6.5 per cent of men have been a victim of stalking at least once during their lifetime.[21]

• Men are more likely to be stalked by another male than a female.[22]

• Women with disability or long-term health conditions are more likely than women without disability or long-term health conditions to experience stalking (3.7 per cent compared to 2.7 per cent over a 12-month period).[23] Women with disabilities also experience greater barriers to reporting and access to services for various reasons, including dependence on the person using stalking for care. This complicates recovery.[24]

• Rates of stalking victimisation for LGBTIQ individuals are high (15 per cent). Transgender, bisexual, and queer people have the highest lifetime prevalence rates of stalking victimisation of the LGBTIQ community. They also have the lowest rates of reporting their victimisation to police, ‘attributed to the risk of discrimination, fear of being outed, fear of homophobic/biphobic/transphobic treatment, and fear that police and the justice system might not recognise the problem.[25]

• There is a lack of accurate prevalence data for rates of stalking among young people. However, previous Australian research has shown the majority of people under 18 years of age who commit stalking are male (64 per cent) while people who are stalked are predominantly female (69 per cent).[26]

1.19 It is less clear from the available evidence how culturally and linguistically diverse communities and Aboriginal and Torres Strait Islander people experience stalking. However, we do know that:

• Stalking is more prevalent among, and has a particular and far-reaching impact upon, Aboriginal and Torres Strait Islander women and girls, their families and their communities. Such violence may be perpetrated by non-Indigenous men as well as Aboriginal and Torres Strait Islander men.[27]

• Stalking offences for the Aboriginal and Torres Strait Islander population are predominantly attributable to family incidents, which increased by 212.5 per cent in the period 2005–2016.[28]

• By contrast, non-family related crimes against the person in Aboriginal and Torres Strait Islander communities decreased over the same period by 7.2 per cent. We are interested to understand whether this indicates possible reluctance to report non-family violence stalking victimisation by Aboriginal and Torres Strait Islander people, and/or inconsistent police responses.

• While it is not clear whether women from culturally and linguistically diverse communities experience stalking at higher rates, the structural, familial and language barriers to accessing support are greater.[29] Multiple people committing stalking may also be involved in this context, and there may be threats of deportation and/or separation from children, making access to the legal system and safety planning more difficult.[30]

• Migrant women with temporary visa status are at heightened risk of technology-facilitated abuse, such as being kept under surveillance.[31] Migrant women commonly experience tracking of their physical movements via location services through social media or applications on smartphones, along with other devices such as car tracking/spyware devices.[32] There is limited research on stalking experienced by migrant women in a non-family violence context.

1.20 The evidence base is also very limited in terms of prevalence rates of stalking committed against public figures or health practitioners. However, what is known is that stalking can continue for many months before the public figure becomes aware of the behaviour, and in most situations where the stalking escalates to physical violence, the person stalking typically does not communicate a threat beforehand.[33] Accurately measuring the risk factors for stalking violence towards prominent people or people with a public profile (such as health practitioners) ‘is difficult because of low base rates’.[34]

Who stalks, how and why?

1.21 People who stalk ‘represent an extremely diverse population’.[35] Typologies classifying people who stalk have been developed by forensic psychiatrists to help understand the context surrounding stalking behaviour, and to guide assessment and management of individuals who stalk.[36] The typologies also ‘act as a kind of shorthand by summarising the risks associated with stalkers from each category’.[37] Researchers have described the three common typologies including the following intersecting characteristics:[38]

1) underlying mental health condition (including comorbidities and dual diagnoses such as substance use disorders)

2) relationship contexts such as intimate partner (current/former), friend (current/former), neighbour, acquaintance, work colleague, school associate or no relationship (stranger)

3) primary motivation (see below).

1.22 ‘Primary motivation’ refers to the main factors contributing to stalking. Emeritus Professor Paul Mullen and colleagues devised the following categories of primary motivations, which capture the diversity of both those who stalk and the possible motivations:[39]

• Rejected stalkers are those with a primary motivation of seeking revenge against, or reconciliation with, the person they are stalking.[40] Rejected stalkers are more likely than any other category of stalker to make threats.[41]

• Intimacy seekers want an intimate relationship with the person they are stalking. This includes people with morbid infatuations and erotomaniac delusions.[42] People who fall within in this category are commonly isolated and socially inept. Intimacy seekers are more likely than any other category to be diagnosed with a mental illness characterised by features of psychosis.[43]

• Entitlement to relationship (incompetent suitors)[44]—This category includes people who feel entitled to a relationship with the person they are stalking. They do not understand that the person they are stalking does not want a relationship with them.[45]

• Resentful stalkers feel wronged by the person they are stalking. Like the rejected stalker, this type is very likely to make threats with the intention of causing fear. They do this to maintain a sense of control.[46] This type of stalker is generally more highly educated than the other types.[47] A distinction found in studies of young people is their potential engagement in stalking behaviours as an extension of bullying or as a more immediate retaliation to a perceived harm, while resentful stalking can be a more long-term behaviour in adults.[48]

• Predatory stalkers target a person with the intention of perpetrating an assault that is typically sexual.[49] These stalkers are almost always men, often with a criminal history.

Example: Entitlement to relationship[50]

A man faced the Magistrates’ Court after breaching bail conditions by continuing to stalk a woman. The man left love letters and approximately 100 Facebook messages for a woman within days of being granted bail. The man was already facing allegations of stalking, assault, abuse using a carriage service and sexual assault against the same woman. The man told police he did not believe his actions would cause fear, and that he loved her.

1.23 The following factors have been shown to increase the risk of non-family violence stalking:

• substance misuse by the person committing stalking

• prior history of violent offending

• explicit threats

• situations where the person committing stalking is driven by rejection.[51]

1.24 No significant differences have been found between stalker types regarding substance misuse.[52]

1.25 A large proportion of people who stalk have not completed high school.[53] Almost half of the stalkers in a large Australian study fell in the low average range or below in tested intelligence scores. This contradicts the stereotype of stalkers being more intelligent than people who commit other kinds of crime.[54] Nevertheless, intimacy seekers and predatory stalkers are more likely to have similar intellectual functioning as the general population.[55]

1.26 There are higher rates of intellectual disability among people who engage in stalking than previously understood. It is important that appropriate assessments are conducted so that the right treatment programs are identified to meet the needs of the individual who has used stalking.[56]

Impact of stalking on victim survivors

1.27 Stalking can cause long-term psychological harms[57] such as depression, anxiety, complex post-traumatic stress disorder, dissociation, eating disorders, and increased suicidality.[58]

1.28 Stalking can affect a person’s quality of life in other ways, including financially, as well as chronic health consequences such as:[59]

• increased risk of gastrointestinal syndromes[60]

• pelvic problems and/or pain during sex

• sleep disorders.[61]

1.29 Victim survivors often experience significant lifestyle changes, such as:[62]

• avoiding places where their stalker might be

• changing routines

• distrust and feelings of lack of safety

• taking additional safety measures

• agoraphobia,[63] social isolation, withdrawal, or attachment problems

• quitting school or their job

• relocating.

  1. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244, 1244.

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  2. Lorraine Sheridan and Graham M Davies, ‘Stalking: The Elusive Crime’ (2001) 6(2) Legal and Criminological Psychology 133; Lorraine Sheridan and Graham M Davies, ‘What Is Stalking? The Match between Legislation and Public Perception’ (2001) 6(1) Legal and Criminological Psychology 3; Lorraine P Sheridan, Eric Blaauw and Graham M Davies, ‘Stalking: Knowns and Unknowns’ (2003) 4(2) Trauma, Violence, & Abuse 148; Lorraine Sheridan and Karl Roberts, ‘Key Questions to Consider in Stalking Cases’ (2011) 29(2) Behavioral Sciences & the Law 255.

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  3. ‘Cyberstalking’, ESafety Commissioner (Web Page) <https://www.esafety.gov.au/key-issues/domestic-family-violence/technology-facilitated-abuse/cyberstalking>.

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  4. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244, 1247.

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  5. Troy McEwan and Michele Pathé, ‘Stalking’ in Gerben Bruinsma and David Weisburd (eds), Encyclopedia of Criminology and Criminal Justice (Springer New York, 2014) 5026-5027.

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  6. Emma Ogilvie and Australian Institute of Criminology, Stalking: Legislation, Policing and Prosecuting in Australia (Australian Institute of Criminology, 2000); Michelle Sibenik, ‘A Critical Analysis of the Applications of Anti-Stalking Legislation in Victoria, Australia’ (PhD Thesis, Monash University, 2018).

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  7. J Reid Meloy and Shona Gothard, ‘Demographic and Clinical Comparison of Obsessional Followers and Offenders with Mental Disorders’ (1995) 152(2) American Journal of Psychiatry 258; Paul E Mullen, Michele Pathé and Rosemary Purcell, ‘Stalking: New Constructions of Human Behaviour’ (2001) 35(1) Australian & New Zealand Journal of Psychiatry 9.

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  8. Based on a real case heard in a Magistrates’ Court in Victoria, with some details changed to protect anonymity.

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  9. ‘Killer Dad’s Emails to Disgraced Private Eye’, NewsComAu (Web Page, 16 May 2021) <https://www.news.com.au/national/nsw-act/courts-law/killer-dad-john-edwards-emailed-to-private-eye-organisation-spousebusters-to-spy-on-wife-inquest/news-story/69e03348b3c1f8338248da23b4c8c942#.8skp2>.

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  10. Private Security Act 2004 (Vic).

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  11. Personal Safety Intervention Orders Act 2010 (Vic) s 10.

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  12. Michelle Sibenik, ‘A Critical Analysis of the Applications of Anti-Stalking Legislation in Victoria, Australia’ (PhD Thesis, Monash University, 2018).

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  13. Jacqui True, ‘The Political Economy of Violence Against Women: A Feminist International Relations Perspective’ (2010) 32(1) Australian Feminist Law Journal 39.

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  14. Heng Choon (Oliver) Chan and Lorraine L Sheridan, Psycho-Criminological Approaches to Stalking Behavior: An International Perspective (John Wiley & Sons, 2020).

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  15. Crime Statistics Agency (Vic), ‘Key Figures: Year Ending December 2020’, Crime Statistics Agency (Web Page, March 2021) <https://www.crimestatistics.vic.gov.au/media-centre/news/key-figures-year-ending-december-2020>.

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  16. The Crime Statistics Agency also captures harassment, private nuisance and threatening behaviour as part of these figures. Crime Statistics Agency (Vic), ‘Recorded Offences’, Crime Statistics Agency (Web Page, September 2020) <https://www.crimestatistics.vic.gov.au/crime-statistics/latest-victorian-crime-data/>.

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  17. Crime Statistics Agency (Vic), ‘Key Figures: Year Ending March 2020’, Crime Statistics Agency (Web Page, June 2020) <https://www.crimestatistics.vic.gov.au/media-centre/news/key-figures-year-ending-march-2020>.

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  18. Magistrates’ Court of Victoria, Annual Report 2018–19 (Report) 41, 52.

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  19. This refers to the number of stalking matters recorded in the Victoria Police LEAP database.

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  20. Australian Bureau of Statistics, Personal Safety, Australia, 2016 (Catalogue No 4906.0, 8 November 2017) <https://www.abs.gov.au/ausstats/abs@.nsf/mf/4906.0>.

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  21. Heng Choon (Oliver) Chan and Lorraine L Sheridan, Psycho-Criminological Approaches to Stalking Behavior: An International Perspective (John Wiley & Sons, 2020); Michelle Sibenik, ‘A Critical Analysis of the Applications of Anti-Stalking Legislation in Victoria, Australia’ (PhD Thesis, Monash University, 2018).

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  22. Australian Bureau of Statistics, Personal Safety, Australia, 2016 (Catalogue No 4906.0, 8 November 2017) <https://www.abs.gov.au/ausstats/abs@.nsf/mf/4906.0>.

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  23. Australian Bureau of Statistics, Experiences of Violence and Personal Safety of People with Disability (Catalogue No 4431.0.55.003, 28 November 2018) <https://www.abs.gov.au/ausstats/abs@.nsf/PrimaryMainFeatures/4431.0.55.003?OpenDocument>.

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  24. Lisa Langenderfer-Magruder et al, ‘Stalking Victimization in LGBTQ Adults: A Brief Report’ (2020) 35(5–6) Journal of Interpersonal Violence 1442, 1443.

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  25. Rosemary Purcell, Teresa Flower and Paul Mullen, ‘Adolescent Stalking: Offence Characteristics and Effectiveness of Intervention Orders’ (Trends & Issues in Crime and Criminal Justice 369, Australian Institute of Criminology, March 2009) <https://www.aic.gov.au/publications/tandi/tandi369>.

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  26. K Cripps et al, Attitudes towards Violence against Women and Gender Equality among Aboriginal People and Torres Strait Islanders—Findings from the 2017 National Community Attitudes towards Violence against Women Survey (NCAS) (ANROWS Insights No 3/2019, 2019) <https://nla.gov.au/nla.obj-1797750465>.

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  27. Crime Statistics Agency (Vic), ‘12-Year Trends in Aboriginal or Torres Strait Islander Offending in Victoria’, Crime Statistics Agency (Web Page, July 2020) <https://www.crimestatistics.vic.gov.au/12-year-trends-in-aboriginal-or-torres-strait-islander-offending-in-victoria>.

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  28. Nicola Henry et al, ‘Technology-Facilitated Domestic Violence Against Immigrant and Refugee Women: A Qualitative Study’ (2021) Journal of Interpersonal Violence 1–27 <https://journals.sagepub.com/doi/abs/10.1177/08862605211001465>.

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  29. Marie Segrave, Temporary Migration and Family Violence: An Analysis of Victimisation, Support and Vulnerability (Report, School of Social Sciences, Monash University, 10 December 2017) <https://apo.org.au/node/114311>; Marie Segrave and Naomi Pfitzner, Family Violence and Temporary Visa Holders during COVID-19 (Report, Monash Gender and Family Violence Prevention Centre, Monash University, 24 September 2020) <https://bridges.monash.edu/articles/online_resource/Family_violence_and_temporary_visa_holders_during_COVID-19/12987938>.

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  30. Bridget Harris, Heather Douglas and Molly Dragiewicz, ‘Migrant Women Are Particularly Vulnerable to Technology-Facilitated Domestic Abuse’, The Conversation (Web Page, 1 February 2019) <http://theconversation.com/migrant-women-are-particularly-vulnerable-to-technology-facilitated-domestic-abuse-110270>.

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  31. Nicola Henry et al, ‘Technology-Facilitated Domestic Violence Against Immigrant and Refugee Women: A Qualitative Study’ (2021) Journal of Interpersonal Violence 127 <https://doi.org/10.1177/08862605211001465>.

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  32. J Reid Meloy, Lorraine Sheridan and Jens Hoffmann, Stalking, Threatening, and Attacking Public Figures: A Psychological and Behavioral Analysis (Oxford University Press, 2008) 6.

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  33. R Ashmore et al, ‘A Survey of Mental Health Nurses’ Experiences of Stalking’ (2006) 13(5) Journal of Psychiatric and Mental Health Nursing 562; David V James et al, ‘Stalkers and Harassers of British Royalty: An Exploration of Proxy Behaviours for Violence’ (2011) 29(1) Behavioral Sciences & the Law 64, 64.

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  34. Daniel Shea, ‘Stalking Recidivism and Risk Assessment’ (Monash University, 2015) 23.

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  35. Kris Mohandie et al, ‘The RECON Typology of Stalking: Reliability and Validity Based Upon a Large Sample of North American Stalkers’ (2006) 51(1) Journal of Forensic Sciences 147; Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244.

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  36. Daniel Shea, ‘Stalking Recidivism and Risk Assessment’ (Monash University, 2015) 23.

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  37. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244.

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  38. Ibid; Christopher Racine and Stephen Billick, ‘Classification Systems for Stalking Behavior’ (2014) 59(1) Journal of Forensic Sciences 250.

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  39. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244.

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  40. Rachel Mackenzie et al, ‘Stalkers and Intelligence: Implications for Treatment’ (2010) 21 Journal of Forensic Psychiatry & Psychology 852.

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  41. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244.

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  42. Rachel Mackenzie et al, ‘Stalkers and Intelligence: Implications for Treatment’ (2010) 21 Journal of Forensic Psychiatry & Psychology 852.

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  43. The term ‘incompetent suitor’, is a term from the literature used to describe the motivations for stalking. It is not intended to describe the impact on victim survivors, which can be significant.

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  44. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244.

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  45. Ibid.

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  46. Rachel Mackenzie et al, ‘Stalkers and Intelligence: Implications for Treatment’ (2010) 21 Journal of Forensic Psychiatry & Psychology 852.

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  47. Rosemary Purcell, Michele Pathé and Paul Mullen, ‘Gender Differences in Stalking Behaviour among Juveniles’ (2010) 21(4) The Journal of Forensic Psychiatry & Psychology 555, 559.

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  48. Paul Mullen et al, ‘Study of Stalkers’ (1999) 156(8) The American Journal of Psychiatry 1244.

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  49. Based on a real stalking case heard in a Magistrates’ Court in Victoria, with some details changed to protect anonymity.

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  50. Frances P Churcher and Marc Nesca, ‘Risk Factors for Violence in Stalking Perpetration: A Meta-Analysis’ (2013) 7(2) FWU Journal of Social Sciences 100; TE McEwan et al, ‘Violence in Stalking Situations’ (2009) 39(9) Psychological Medicine 1469; Troy E McEwan et al, ‘Risk Factors for Stalking Violence, Persistence, and Recurrence’ (2017) 28(1) Journal of Forensic Psychiatry & Psychology 38; Troy McEwan, Paul E Mullen and Rosemary Purcell, ‘Identifying Risk Factors in Stalking: A Review of Current Research’ (2007) 30(1) International Journal of Law and Psychiatry 1.

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  51. Rachel Mackenzie et al, ‘Stalkers and Intelligence: Implications for Treatment’ (2010) 21 Journal of Forensic Psychiatry & Psychology 852.

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  52. Ibid.

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  53. Ibid.

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  54. Ibid.

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  55. Ibid.

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  56. Jenny Korkodeilou, ‘“No Place to Hide”: Stalking Victimisation and Its Psycho-Social Effects’ (2017) 23(1) International Review of Victimology 17.

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  57. Ibid.

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  58. Paul E Mullen, Michele Pathé and Rosemary Purcell, Stalkers and Their Victims (Cambridge University Press, 2008).

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  59. Daniela Acquadro Maran et al, ‘Characteristics of the Stalking Campaign: Consequences and Coping Strategies for Men and Women That Report Their Victimization to Police’ (2020) 15(2) PLOS ONE e0229830: 1–14.

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  60. Ibid.

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  61. Jenny Korkodeilou, ‘“No Place to Hide”: Stalking Victimisation and Its Psycho-Social Effects’ (2017) 23(1) International Review of Victimology 17.

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  62. Daniela Acquadro Maran et al, ‘Characteristics of the Stalking Campaign: Consequences and Coping Strategies for Men and Women That Report Their Victimization to Police’ (2020) 15(2) PLOS ONE e0229830: 1–14.

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