Mail Order Brides and the Abuse of Immigrant Women
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A License To Abuse:
The Impact of Conditional Status on Female Immigrants
by Michelle J. Anderson

[Text and footnotes of this article are reprinted from The Yale Law Journal. Volume 102 . April 1993 . Number 6. Copyright (c) 1993 by The Yale Law Journal Co., Inc.]

Maria was born in the Dominican Republic. She married a United States citizen, immigrated to this country, and obtained "conditional" resident immigration status, which enabled her to remain legally in the United States provided that she stay wedded to her spouse. Soon afterward, her husband began to brutalize her physically. "One time I had eight stitches in my head and a gash on the other side of my head, and he broke my ribs.... He would bash my head against the wall while we had sex. He kept threatening to kill me if I told the doctor what happened."(1) Afraid of the risk of deportation, Maria endured her husband's treatment for months. After she finally fled, her spouse demanded that she return to his apartment for her immigration documents. At first, she told him, "No, you're going to hit me." But then she realized that she had to go because she needed the papers. She described the consequences: "He beat me on the head. He sat on my stomach. He put a knife to my throat and raped me. Then he threw me naked on the street."(2)

Sue,(3) a Chinese -national, immigrated and obtained conditional residency after marrying a U.S. citizen. Like Maria, Sue had to remain married to maintain her legal immigration status. Unfortunately, the similarities did not end there. Sue's husband repeatedly beat her. "You do exactly what I say, or I'll call Immigration," her husband warned, kicking her in the neck and face. "You need me." Sue feared she would not live. "Her story is typical of the battered immigrant women we see," explains Beckie Masaki, Executive Director of San Francisco's Asian Women's Shelter. "The batterer uses his citizenship to control and humiliate his wife."(4) Pat Eng, founder of the New York Asian Women's Center, concurs, "Batterers invariably use[ ] the threat of deportation as a weapon in the abuse of their alien wives."(5)

Female conditional residents are at risk for abuse due not only to their status as women in a culture in which violence against women is relatively common,(6) but also to their position as immigrants who marry citizens or legal permanent residents (LPR' s).(7) Studies vary widely in estimating the percentage (between 12-50%) of all married women who experience some form of domestic battery in their lives.(8) Whatever the rate in the general population, the percentage for immigrant women is probably higher.(9) Linguistic and cultural differences between spouses may hamper communication, tolerance, and understanding.(10) The immigrant wife may be economically(11) and psychologically(12) dependent upon her spouse, limiting her alternatives to the relationship and placing her at increased risk for domestic violence.(13) Stresses associated with migration itself, discrimination against racial minorities in this country, poverty, unemployment, and crowded living conditions heighten the chance that a husband will become abusive.(14) Forty-eight percent of Latinas in a Coalition for Immigrant Rights and Services study reported that domestic violence against them had increased since they immigrated to the United States.(15) Therefore, conditional resident status affects the lives of women who already face an enhanced risk of domestic violence from their partners.

A statute designed to combat an exaggerated claim of marital fraud, a well-intentioned amendment to limit the statute's draconian effects on battered women, and a meager interpretation of that amendment by the Immigration and Naturalization Service (INS) constitute the conditional residency laws that affect the lives of immigrant women. Like prior laws, but with new presumptions and procedures, the Immigration Marriage Fraud Amendments (IMFA) of 1986 authorize the INS to scrutinize immigrants' nuptial ties to citizens or LPR's in an effort to discover and deport any alien who obtained immigration status fraudulently, through a bogus marriage. Under the IMFA, when a citizen or LPR files a petition with the INS requesting residence for his, immigrant spouse, and the qualifying marriage is less than two years old,(16) the INS awards the immigrant conditional residence. Under conditional residence, the marriage must remain intact for at least two years; otherwise, the immigrant spouse loses her legal status, and becomes deportable. Because an immigrant cannot petition for her own conditional status, battered wives can be trapped in something less than wedded bliss. In 1988, Congress amended the IMFA in an attempt to correct this problem by allowing women who could prove they were battered to adjust from conditional to legal permanent resident status. That amendment was too limited in scope, however, and too narrowly interpreted by the INS. Congress' original attempt to regulate marriage fraud and its legislative and regulatory progeny have thus inadvertently increased abusers' coercive power over conditional resident spouses.

Part I of this Note portrays difficulties facing certain immigrant women by describing two subpopulations of female conditional residents: military brides and so-called "mail-order brides." Part II describes the statutory and regulatory scheme governing immigrant women, including the IMFA of 1986 that Congress enacted to curb illegitimate immigration,(17) the amendment to the statute in 1988,(18) and subsequent INS regulations implementing these laws.(19) Part III argues that the current statutory and regulatory framework exacerbates immigrant women's dependence upon their spouses, establishes unreasonable evidentiary requirements, and ignores community barriers and immigrants' fear of bureaucratic entanglement. Part IV urges that we solve these problems by allowing women to petition for immigration status, establishing reasonable evidentiary requirements, and encouraging confident interaction with bureaucracy.(20) Some proposed solutions would require only new INS regulations that conform with statutory intent, while others would require Congress to amend the present statutory scheme. Part V analyzes the likely impact of these proposed changes.


Foreign nationals can come to marry U.S. citizens or LPR's in a variety of ways. For example, a citizen may live overseas for some time, marry, and then bring the spouse to the United States, as occasionally occurs with military wives. Sometimes foreign nationals and U.S. citizens or LPR's first come to know each other entirely through the mail, after which the foreign national immigrates and marries, as with many mail-order bride unions. In other circumstances, a foreign national enters the United States on a student, tourist, business, or other visa, marries, or simply remains in this country beyond his or her visa limits, and then weds a legal resident. Other immigrants reside in the United States illegally for some time and then marry citizens or LPR's.

Unique stresses can arise when two people from different cultures marry. Two types of intercultural relationships illustrate some reasons why immigrant women may be particularly susceptible to abuse in these circumstances: marriages involving military and mail-order brides. These conditional residents are not the only immigrant women at risk of battery. Their problems, however, illustrate the power disparity and particular stresses that may operate in families in which conditional resident status applies.

A. Military Brides

Men stationed overseas in the armed forces may marry women born in foreign countries, sometimes referred to as "war brides." As a result of the deployment of U.S. troops in Asian countries, for example, over 200,000 Japanese, Vietnamese, Thai, Korean, and Filipino women have married U.S. servicemen and immigrated to the United States since World War II.(21)

The frequency of abuse in military families is proportionally much greater than in civilian families.(22) Various stresses associated with military life contribute to the increased risk of battery. The transient nature of military service increases social isolation, preventing family members from establishing roots in a community."(23) Employment and financial pressures, as well as extended separation when active duty soldiers are stationed away from home, add pressure to these families' lives.(24) Perhaps most significant, aggressive values indoctrinated into soldiers encourage them to use physical force to express displeasure when faced with domestic problems.(25)

The severity of domestic abuse in military families "makes the usual" patterns of violence in civilian families pale by comparison.(26) In one study, for instance, those employed in the military used weapons on their wives almost twice as often as civilian batterers, and "three-fourths of the military cases were in the dangerously life-endangering category compared to only about one-third of the civilian cases."(27) Researchers have concluded that "[t]he worst of the civilian cases were the norm for the military cases."(28) What is more, since military wives are traditionally expected to participate in and support their husbands' careers, thus playing a special role in the success or failure of those careers,(29) wives are generally reluctant to report spousal abuse to the military police or other authorities."(30)

These problems may be exacerbated for immigrant women. In addition to aggressive military indoctrination, cultural and linguistic differences between the partners can impede communication and increase frustration.(31) Without the nearby support of family and friends, immigrant women are isolated in a foreign environment.(32) Captain Nancy K. Raiha, an army social worker, explains:

In any intercultural marriage differences in norms, values, expectations, and habits may lead to tension and conflict. Social pressures (i.e. discrimination) are sometimes an additional burden to the interracial couple.... Couples who are unable to communicate verbally seem more likely in some cases to resort to physical means of expressing displeasure and frustration.(33)

These stresses on the military family relationship increase the risk that "men who already have a proclivity for acting out their anger" will do so.(34)

One woman's situation typifies the problems immigrants may face as military brides. Merta met her husband while he was stationed in Greece. They married and moved to Texas. Merta spoke little English. Her husband was obsessively jealous and controlling, and he forbade her to leave the house. Playing on her media-inspired image of the United States, he warned her that the outside world was a "death trap." She was forbidden to leave his side or speak to anyone, and he beat her routinely. Not long before she escaped the relationship, Merta's husband had won a "Sergeant of the Year" award.(35)

B. Mail-Order Brides

"Mail-order brides," women who are advertised in catalogs (the most popular of which is entitled Cherry Blossoms)(36) for marriage to American men, generally come from destitute conditions in parts of Asia."(37) Most are born in the Philippines, a country troubled by political strife and high unemployment."(38) Over 70% of Philippine women live in poverty, thus making them particularly vulnerable to the mail-order industry.(39)

The mail-order bride business appears to be thriving.(40) Approximately 200 companies operate in the United States(41) and an estimated 2000 to 3500 American men find wives through these catalogs each year.(42) In June 1990, the government of the Philippines, alarmed at reports of widespread abuse of Philippine women in other countries, outlawed bride agencies. That move simply drove the mail-order business underground without significantly affecting the international trade.(43)

Mail-order bride relationships begin when a company travels to the Philippines (or another economically troubled country) to recruit women for its catalogs.(44) Bolstered by the promise of a glamorous life in the United States,(45) the company convinces multitudes of young Philippine women(46) to list themselves. Typically, an older American man,(47) having become disenchanted with the changing gender roles of the past few decades,(48) joins a mail-order bride club to find a "beautiful, faithful, Asian Wife."(49) The company sends him a catalog with the pictures, vital statistics, and addresses of potential mates. The man usually conducts a mass mailing to women he finds appealing and continues to write to promising prospects, hoping to "woo" one into marriage."(50) Alternatively, the industry encourages him to travel to the Philippines, mail-order catalogs in hand, to track down women using their listed addresses.(51) Mail-order catalogs offer men scripts to use once in the presence of these women. If all else fails, one publisher explains, a man must be a "beast type." "If she can't be taken by [more subtle] tactics, use speed and force," he writes.(52) "As it is said, action is better than words. But I say, 'action with the combination of words are, the best.' But be careful because you might be charged with rape and risk your reputation."(53)

When these cross-cultural interchanges do result in marriage, unrealistic expectations on both sides often mean severe incompatibility at best, and outright abuse at worst.(54) As Carmencita Hernandez, Chair of the Women's Committee of the National Council of Canadian-Filipino Associations, explains, "[w]hen a Filipino woman--who is stereotyped as meek--stands up for herself, the trouble begins."(55) In one case, a twenty-two-year-old woman named Ngan married a U.S. citizen and immigrated to this country. Ngan was not the picture bride her husband believed he had ordered. "The first time he beat me, I was too afraid to do anything about it," she said. The second assault drew blood. Her neighbors took her to the hospital, and then to an Asian battered women's shelter.(56)

The story of a twenty-four-year-old woman named Raco offers another example. Raco married a U.S. citizen who had courted her by mail for ten years. Soon after she came to this country, he began to beat her because of differences she had with his parents. His assaults worsened because she did not want to bear children immediately. When she became pregnant, "[h]e threatened not to sponsor me for permanent residence if I didn't carry the pregnancy to term," she said. But the violence escalated, even after she decided to have the baby.(57) When she was, six-months pregnant, he beat her so fiercely that she feared for the life of her unborn child and fled to a shelter.(58)

What mail-order brides such as Ngan and Raco have in common with military wives such as Merta is that they are all conditional residents. They face the problems of a statutory framework that gives much of the control over their immigration status to their abusive spouses.

Continued on Page II


(1) Vivienne Wait, Immigrant Abuse: Nowhere to Hide, NEWSDAY, Dec. 2, 1990, at 8. BACK

(2) Id. The severe abuse Maria endured after fleeing her battering relationship is consistent with patterns of increased abuse when women attempt to terminate or just after women terminate battering relationships. See Martha R. Mahoney, Legal Images of Battered Women: Redefining the Issue of Separation, 90 MICH. L. REV. 1, 61-75 (1991) (defining "separation assault" and describing the incidence of separation attacks); Margo Wilson &  Martin Daly, Till Death Us Do Part, in FEMICIDE: THE POLITICS OF WOMAN KILLING 83, 89 (Jill Radford & Diana E.H. Russell eds., 1992) [hereinafter FEMICIDE]. BACK

(3) Not her real name. BACK

(4) Deanna Hodgin, 'Mail-Order' Brides Marry Pain to Get Green Cards, WASH. TIMES, Apr. 16, 1991, at E1; see also Jorge Banales, Abuse Among Immigrants: As Their Numbers Increase So Does the Need for Services, WASH. POST, Oct. 16, 1990, at E5 ("The 1986 Immigration Reform Act and the Immigration Marriage Fraud Amendment have combined to give the spouse applying for permanent residence a powerful tool to control his partner."); Nancy A., Fellom, Fear and Loathing in.America: Alien Spouses Held Hostage Under Threat of Deportation Are Rescued from Abusive Partners by Amendments to Immigration Act, RECORDER, Aug. 15, 1991, at 4 (pointing out that immigrant remained "almost completely dependent on the continued goodwill of the resident benefactor, under threat of deportation if [she] went against [his] will"). For other stories of battered conditional residents, see CHRIS HOGELAND & KAREN ROSEN, DREAMS LOST, DREAMS FOUND: UNDOCUMENTED WOMEN IN THE LAND OF OPPORTUNITY 12-13 (1991); Rachel Morello Frosch & Trinidad Madrigal, Introduction to DOMESTIC VIOLENCE IN IMMIGRANT AND REFUGEE COMMUNITIES: ASSERTING THE RIGHTS OF BATTERED WOMEN 1-1, 2 (Deeana Jang et al. eds., 1991) [hereinafter DOMESTIC VIOLENCE]. BACK

(5) Hodgin, supra note 4; see also Debbie Lee, Identifying Immigrant Battered Women, in DOMESTIC VIOLENCE, supra note 4, at II-3. BACK

(6) See, e.g., Wilson & Daly, supra note 2, at 96 ("Women in the United States today face a statistical risk of being slain by their husbands that is about five to ten times greater than that faced by their European counterparts, and in the most violent American cities, the risk is five times higher again."); Janet Bass, More Women Raped in 1990 than Any Year in U.S. History, UPI, March 22, 1991, available in LEXIS, Nexis Library, UPI File (despite cross-national reporting differences which may account for some of the disparity, surveys indicate that "[t]he 1990 U.S. rape rate was 20 times higher than in Portugal, 26 times higher than in Japan, 15 times higher than in England, eight times higher than in France, 23 times higher than in Italy and 46 times higher than in Greece"). Furthermore, the incidence of rape in this country may be rising. See Survey Shows Rape Leads Violent-Crime Increase, N.Y. TIMES, Apr. 20, 1992, at B 12 (citing an estimate from the Bureau of Justice Statistics that puts number of rapes and attempted rapes in 1991 up 59% from the previous year); Eloise Salho1z, Women Under Assault, NEWSWEEK, July 16, 1990, at 23 (citing FBI statistics that show rape rate "increasing at four times the rate of other crimes"). The increased numbers may not be solely attributable to increased reporting rates. See, e.g., Jane Caputi & Diana E.H. Russell, Femicide: Sexist Terrorism against Women, in FEMICIDE, supra note 2, at 16-17 (documenting dramatic increase in the incidence of unreported violence against women over the past 50 years); Michael Isikoff, Record Number of Rapes Reported in U.S. in '90, WASH. POST, Mar. 22, 199 1, at A3 (citing Senate Judiciary Committee national study revealing dramatic increase in unreported rapes which concludes, "This data ... silences the skeptics who believe that the rising rape rates are nothing more than a function of more women reporting their rapes to the police."). BACK

(7) Though the arguments presented in this Note also apply to abused conditional residents who are male, I address the plight of female conditional residents for two reasons. First, in the past 30 years, women have consistently comprised a majority of all documented and undocumented immigrants to the United States. Marion F. Housten et al., Female Predominance in Immigration to the United States Since 1930: A First Look, 18 INT'L MIGRATION REV. 908, 913, 922 (1984). Second, women comprise the vast majority of the victims of domestic assault. LEWIS OKUN, WOMAN ABUSE: FACTS REPLACING MYTHS 39-42 (1986). Though women can physically assault men, Dr. Angela Browne of the University of Massachusetts Medical School points out that "[w]omen abused by male partners tend to sustain multiple injuries to multiple sites of the body, an injury pattern not seen in men assaulted by female partners." Tamar Lewin, Battered Men Sounding Equal-Rights Battle Cry, N.Y. TIMES, Apr. 20, 1992, at A12. BACK

(8) For a survey of the available studies documenting the incidence of domestic battery, see ROBERT T. SIGLER, DOMESTIC VIOLENCE IN CONTEXT: AN ASSESSMENT OF COMMUNITY ATTITUDES 12-13 (1989); see also OKUN, supra note 7, at 37-39; MILDRED DALEY PAGELOW, FAMILY VIOLENCE 42-46 (1984). BACK

(9) Exact numbers are difficult to gauge, but various reports suggest that the population of abused immigrant women is very large. Preliminary data from a random sample survey of 157 undocumented Latinas in the D.C. metropolitan area indicates, for instance, that 60% of undocumented women report that they are battered by their spouses. Of those women who are married to citizens or LPRs (but have not obtained conditional resident status), the rate is reported at 77%. Telephone Interview with Leslye Orloff, Director of Program Development, Ayuda of Washington D.C. (Mar. 23, 1993). See also James Leung, Law Benefiting Immigrant Wives Means More Work for Shelter, S.F. CHRON., Feb. 20, 1991, at B12 (indicating that domestic violence problem is on the rise); Wendy Lin, Is INS Hindering Abused Wives? Rules Said to Undermine Law Meant to Help Them, NEWSDAY, July 8, 1991, at 21 (noting that in 1990 half of battered clients at New York Asian Women's Center in Manhattan were conditional residents and 90% of victims of domestic violence at the Victims' Services Agency office in Jackson Heights, Queens were immigrants); see also Telephone Interview with Debbie Lee, Senior Program Coordinator, Family Violence Prevention Fund of San Francisco, Cal. (Mar. 10, 1992) [hereinafter Lee Interview] (characterizing battered conditional residents as "hidden population"). BACK

(10) See infra notes 31-33 and accompanying text. BACK

(11) Often conditional residents lack independent financial resources. See Fellom, supra note 4 ("The declining budgets and shrinking resources of social services agencies, coupled with language barriers, are very real obstacles for immigrant women and children, many of whom live at or below the poverty level. There are often no close friends or family to assist."); see also infra note 106 and accompanying text. BACK

(12) Often conditional residents do not have a sense of the social and legal realities of a highly bureaucratic state. Estelle Chun, Deputy Director of the Asian Pacific American Legal Center in Los Angeles, explains,

Battered conditional spouses often think that if they flee an abusive husband, the husband can just snap his fingers and the INS will come knocking at the door to put them on a plane the next day for their old country. The citizen is much more sophisticated about the laws and the culture; the immigrant often cannot speak English. The exploitation is so apparent.

Telephone Interview with Estelle Chun, Deputy Director of the Asian Pacific American Legal Center of Los Angeles, Cal. (Mar. 10, 1992) [hereinafter Chun Interview]; see also HOGELAND & ROSEN, supra note 4, at 16 (discussing dependence inhibiting battered. immigrant from seeking help) and 19 (discussing widespread misinformation in immigrant communities); Frosch & Madrigal, Introduction to DOMISTIC VIOLENCE, supra note 4, at 1-1; Debbie Lee, Identifying Immigrant Battered Women, in DOMESTIC VIOLENCE, supra note 4, at II-2. BACK

(13)[W]omen whose dependency on marriage is high tend to experience more physical abuse from their husbands than women whose dependency is low... [W]ives who are highly dependent on marriage are less able to discourage, avoid, or put an end to abuse than are women in marriages where the balance of resources between husbands and wives is more nearly equal. Dependent wives have fewer alternatives to marriage and fewer resources within the marriage with which to negotiate changes in their husbands' behavior. Thus marital  dependency reinforces the likelihood that women will tolerate physical abuse from their husbands.

Debra S. Kalmuss & Murray A. Straus, Wife's Marital Dependency and Wife Abuse in PHYSICAL VIOLENCE IN AMERICAN FAMILIES 369, 379 (Murray A. Straus & Richard J. Gelles eds., 1990) [hereinafter PHYSICAL VIOLENCE].
     Some psychologists embrace a theory of an abused woman's mental state called the "battered woman syndrome." In a pattern of learned helplessness, an individual, perceiving no correlation between her behavior and the abuse she sustains, may come to believe that she has little or no control in her life. Lenore E. Averbach, What Counselors Should Know about the Battered Woman, in THE MALE BATTERER: A TREATMENT APPROACH 158-160 (Daniel Jay Sonkin et al, eds., 1985) [hereinafter THE MALE BATTERER]. But the "battered women syndrome" cannot fully explain or adequately address the experience of many women of color. See, e.g., Sharon A. Allard, Rethinking Battered Woman Syndrome: A Black Feminist Perspective, 1 UCLA WOMEN'S L.J. 191, 205, 206 (1991). BACK

(14) Migration places stress on families, which may increase the odds that a husband will act violently toward his spouse. See HOGELAND & ROSEN, supra note 4, at 15-16; Jorge Banales, Riots Show Latino Immigrants' Alienation, UPI, May 7, 1991, available in LEXIS, Nexis Library, UPI File; Banales, supra note 4. These facts, of course, do not excuse battery; they simply shed light on why it happens. BACK

(15) Leslye Orloff, Domestic Violence Cases Involving Immigrant and Refugee Communities: The Response of the Courts, in Family Violence: Issues of Public Policy and Government Practice (forthcoming) (manuscript at 4, on file with author) (noting that 52% of those women are still living with their abusive partners). BACK

(16) 8 C.F.R. § 216.1 (1992) (defining conditional resident as an "alien who has been lawfully admitted for permanent residence [as a spouse] ... subject to the conditions and responsibilities set forth ... in this chapter"). BACK

(17) 8 U.S.C. §§ 1184(d), 1186a (1988). BACK

(18) 8 U.S.C. § 1186a(c)(4) (1990 Supp. II). BACK

(19) 8 C.F.R. § 216 (1992). BACK

(20) On July 24, 1992, Representatives Mazzoli and Slaughter introduced a bill in Congress, H.R. 5693, to solve many of the problems I outline in this Note. Unfortunately, the bill did not pass. BACK



(23) SHUPE ET AL., supra note 22, at 67, 69; The Male Batterer: An Overview, in THE MALE BATTERER, supra note 13, at 51. BACK

(24) The Male Batterer: An Overview, in THE MALE BATTERER supra note 13, at 51-52. For military wives, employment is difficult to obtain. See STONE & ALT, supra note 21, at 151-58, 163 (stating that "unemployment rate for military wives is sometimes triple that of civilians"). BACK

(25) SHUPE ET AL., supra note 22, at 67 (noting that heavy emphasis in military training or "masculinity and aggressiveness" has proven to be important component of male violence toward women in research on civilian couples as well); STONE & ALT, supra note 21, at 110- 111; The Male Batterer: At Overview, in THE MALE BATTERER, supra note 13, at 50. BACK

(26) SHUPE ET AL., supra note 22, at 67. BACK

(27) Id. at 76, 79. BACK

(28) Id. at 77. BACK

(29) Id. at 70. BACK

(30) Id. See also STONE & ALT, supra note 21, at 106-07 (discussing career ramifications--from verbal reprimand to demotion to being declared unfit for service--of wife's report of domestic assault). BACK

(31) AMOTT & MATTHAEI, supra note 21, at 253; STONE & ALT, supra note 21, at 144; The Male Batterer: An Overview, in THE MALE BATTERER, supra note 13, at 51. BACK

(32) Amon & MATTHAEI, supra note 21, at 253; The Male Batterer: An Overview, in THE MALE BATTERER, supra note 13, at 51; Venny Villapando, The Business of Selling Mail-Order Brides, in MAKING WAVES: AN ANTHOLOGY OF WRITING BY AND ABOUT ASIAN AMERICAN WOMEN 318, 319 (Asian Women United of California ed., 1989). BACK

(33) SHUPE ET AL., supra note 22, at 75. BACK

(34) The Male Batterer: An Overview, in THE MALE BATTERER, supra note 13, at 51. BACK

(35) SHUPE ET AL., supra note 22, at 75. BACK

(36) The term "mail-order bride" may contribute to the conceptualization and treatment of Asian women as exotic, fungible commodities instead of individuals. Villapando, supra note 32, at 325; Charles McCue, She's No Suzy Wong, GANNET NEWS SERVICE, Apr. 22, 1991. BACK

(37) HOGELAND & ROSEN, supra note 4, at 7-8; Hodgin, supra note 4. BACK

(38) Hodgin, supra note 4. BACK

(39) HOGELAND & ROSEN, supra note 4, at 7; see also Villapando, supra note 32, at 322. BACK

(40) Hodgin, supra note 4 (noting that Nihonmachi Legal Outreach Center in San Francisco, an Asian immigrant advocacy group, has observed recent increase in the industry); James Leung, Many Mail-Order Brides Find Intimidation, Abuse: Marriages Made in China for U.S. Citizenship, S.F. CHRON., Sept. 4, 1990, at A9 (reporting that Chinese-language newspapers are full of advertisements for mail-order brides). BACK

(41) Melinda Henneberger, Well, the Ukraine Girls Really Knock Them Out, N.Y. TIMES, Nov. 15, 1992, at E6; see also Jon McKenna, How to Find Women 'Who Would Marry Dear Old Dad,' ATLANTA BUS., CHRON., Mar. 26, 1990, at A3 (estimating 50 mail-order bride businesses). BACK

(42) AMOTT & MATTHAEI, supra note 21, at 254; Cynthia Kadohata, More Than He Bargained For, N.Y. TIMES, Jan. 7, 1990, § 7 (Book Reviews), at 15; see also Henneberger, supra note 41 (reporting that in 1991, 100 mail-order brides immigrated to New York alone). BACK

(43) Philippines: Stops "Mail-Order Bride" Trade, INTER PRESS SERVICE, June 14, 1990, available in LEXIS, Nexis Library, Inter Press Service File. The law provides penalties of up to 8 years in prison and $1000 in fines. BACK

(44) Philippine women comprise 87% of the women recently featured in a popular mail-order bride catalog. U.S.-ASIAN CONNECTION, PROMOTIONAL LETTER, Feb., 1993, at 1. BACK

(45) Villapando, supra note 32, at 320-22. BACK

(46) A 19-year-old seeks "a lifetime partner aged 30-50," while a 17-year-old "seeks friends aged 30 and above." U.S.-ASIAN CONNECTION, PROMOTIONAL CATALOG, Oct. 1992, at 16. A 24-year-old seeks a "lifetime partner aged 25-60" Id., Feb. 1993, at 1. It is not unreasonable to assume that catalog companies coach young women to indicate a preference for older men--the catalogs' main customers. See infra note 47. Some females advertised are as young as 13 years old. Paul Watson, Mail-Order Bride Firms Flourish in Canada, TORONTO STAR, Nov. 9, 1992, at Al. BACK

(47) Most men using the mail-order bride business are older and divorced. One industry brochure claims that "a[ ] pleasant difference [between Philippine and American women] is [the former's] willingness to accept and often times their preference for older men. Many Filipinas prefer a man who is 5, 10, 20 or more years their senior. Many Asian cultures seem to have a great respect for older and wiser people." MARITES LEWIS, & STEVEN LEWIS, HOW TO FIND A BEAUTIFUL, FAITHFUL ASIAN WIFE 16 (1991). Although the mail-order marriage industry claims that Asian women prefer to be much younger than their partners, a large age disparity can be a great source of stress in a relationship, and, thus, one factor associated with domestic assault. See, e.g., Wilson & Daly, supra note, 2, at 95 (discussing large age disparity between, husband and wife associated with domestic homicide). BACK

(48) These men typically view the women's movement as the reason they cannot maintain satisfactory relationships with women. Henneberger, supra note 41 (stating that mail-order bride industry "was renewed, the brokers say, in the 1970's, when men who considered themselves casualties of the American women's movement began looking overseas for more traditional wives"). Promotional material for one mail-order bride catalog boasts a letter from a happily married "Marcus" who explains that, "[I]t is, easy to understand why so many European., Australian, and American men are going [to the Philippines] to select their wives. Unlike American women, most Filipinas are virgins up until the day they are married .... Filipinas are more caring, loving, devoted to their husband & children, understanding, and responsible than American women . . . . They have much more concern for the family unit and are against the idea of divorce." U.S.-ASIAN CONNECTION, PROMOTIONAL MATERIALS, Fall 1992 Update (claiming that the letter "is typical of the well over 200 confirmed marriages resulting from our service"').
     Such motivations appear to be shared internationally. One Canadian consumer of mail-order bride catalogs laments the "overly liberated North American females" by stating, "Filipino women still have a lot of the old traditions in them, eh? ... They walk behind you where Canadian girls walk all over you." A Canadian mail-order bride publisher notes that "[t]his female liberation has done a  lot for the females, but it sure hasn't done much for the fellow who's looking for a wife." Watson, supra note 46. In Japan, where some 20,000 mail-order brides immigrated over the last five years, "non-Japanese Asian women are popular with Japanese men because they are considered easier to control than their Japanese counterparts." Suvendrini Kakuchi, Japan: Landmark Court Ruling Upholds Rights of 'Mail Order' Brides, INTER PRESS SERVICE, Feb. 21, 1991, available in LEXIS, Nexis Library, Inter Press Service File. In Australia, where one report claims that 20% of the immigrant women marrying Australian residents are Philippine, many men choose mail-order brides because of a "stereotypical image . . . of Filipino women as being domesticated and subservient."' Kalinga Seneviratne, Australia: Filipino Mail Order Brides End Up Being Murdered, INTER PRESS SERVICE, July 20, 1991, available in LEXIS, Nexis Library, Inter Press Service File.
     Abuse of mail-order brides is common in other countries, as well. In the past few years, for example, there have been I I officially acknowledged cases of Australian husbands murdering their Philippine mail-order brides. Id. BACK

(49) See generally LEWIS & LEWIS, supra note 47. Both  "mail-order brides" and their browsing grooms" are tutored in how to discover and obtain the ideal mate. Catalog companies laud the obsequiousness "inherently natural in an Oriental." Watson, supra note 46. And where what is "natural" for an "Oriental" leaves off, the mail-order bride industry picks up. Catalog publishers coach women in deferential mannerisms to please potential mates. Villapando, supra note 32, at 318-19, 322. The stereotype of the geisha girl is not shattered until the marriage is consummated. McCue, supra note 36. Women are described in catalogs as "likes to cook," "likes to sew," "likes home," "likes to keep house," or "enjoys household chores." U.S.-ASIAN CONNECTION, PROMOTIONAL CATALOG, Oct., 1992, at 16. In contrast, in a new "Russian ladies" catalog, the women express such interests as "enjoys psychology, art, travel, and nature." One company affords Russian women, unlike Philippine women, an opportunity to describe their "ideal man." One woman indicated that her ideal would be "age 25-35; courageous, prosperous, blond and sports minded;" another wanted someone "educated, clever and kind." U.S.-ASIAN CONNECTION,  RUSSIAN PROMOTIONAL CATALOG, Feb. 1993, at 2. BACK

(50) Men are instructed in various wooing techniques, including the "shotgun approach"' whereby a browser performs a mass mailing of photocopied letters to numerous women indicating his interest in them; a sample letter is provided, and men are told to employ generic greetings, such as "Dear Pretty Lady." LEWIS & LEWIS, supra note 47, at 8; Henneberger, supra note 41 (noting that "the purveyors of marital bliss suggest that volume is the key to finding a match"). For a bit extra, a man can pay the company to do the time-consuming business of letter-writing or gift-buying to woo prospective mates. Villapando, supra note 32, at 320-2 1. Some companies will write a man's personals ad as well; see U.S. ASIAN CONNECTION, ORDER FORM, 1993 ("We can compose your ad for you if you would prefer."). BACK

(51) The industry encourages: "With 100's of young ladies in each of your issues you really have almost unlimited possibilities." An efficient method of pursuing the women once in the Philippines, one company urges, is to hire a taxicab driver and "just relax in the ... air conditioned hotels" while the cab driver "battle[s] the traffic and heat" to locate women. "The worst that could happen is that the young lady could tell the cab driver that she is already engaged or married. The cab driver could simply cross off her name and go find the next young lady on your list." LEWIS & LEWIS, supra note 47, at 30. Some Australian men have taken to importing multiple fiancees on short visas and then sending them back when their visas expire, only to sponsor another Australian welfare workers report that many Australian men boast that it. is "cheaper to get an Asian wife than to get an Australian prostitute." Seneviratne, supra note 48. BACK

(52) Watson, supra note 46. BACK

(53) Id. BACK

(54) Villapando, supra note 32, at 325. BACK

(55) Filipino Canadians Urged to Speak Up about Abuse, GAZETTE (MONTREAL), Feb. 23, 1992, at A3; see also Henneberger, supra note 41 ("The exotic charm of a distant correspondent can fade abruptly in the reality of culture shock and life with a stranger. Many of the prospective brides end up being deported. And the women, who are often quite young and speak little English, also, risk isolation and abandonment if not outright abuse from men they have known only through letters."). BACK

(56) Leung, Many Mail-Order Brides Find Intimidation, Abuse: Marriages Made in China for U.S. Citizenship, supra note 40, at A9. BACK

(57) Studies have shown that abusive husbands become more violent when their partners become pregnant. Richard J. Gelles, Violence and Pregnancy: Are Pregnant Women at Greater Risk of Abuse? in PHYSICAL VIOLENCE, supra note 13, at 282-83 ("Pregnant women's risk of abusive violence was 60.6% greater than that of nonpregnant women, while the overall risk of any form of violence to pregnant women was 35.6% greater than that of nonpregnant women. Not only did pregnant women report higher rates of violence, but men with pregnant wives or partners reported that they were more violent to their partners than were men married to women who were not pregnant at the time, of the interview."); see also Diane Bohn, Domestic Violence and Pregnancy, 35 J. NURSE-MIDWIFERY 86, 88-91 (1990); Judith McFarlane, Battering During Pregnancy: Tip of an Iceberg Revealed, 15 WOMEN & HEALTH 69, 71-72 (1989). BACK

(58) Marvine Howe, Battered Alien Spouses Find a Way to Escape an Immigration Trap, N.Y. TIMES, Aug. 25, 1991, at A40. BACK

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