
Self-control and strain perspectives are widely viewed as independent and contrasting explanations for crime and delinquency. This paper re-evaluates the competing paradigms approach by considering the two theories as potentially complementary in explaining participation in delinquency based on Gottfredson and Hirschi's (1990) assumption that self-control acts as a barrier to criminal behaviour. If such a claim is valid, one would hypothesize that individuals with high self-control would be able to mediate the effects of strain and refrain from engaging in delinquent activities. In contrast, adolescents with low self-control may not be equipped with the necessary constraints to abstain from delinquency and would therefore exhibit the greatest criminal propensities. A significant interaction term would support such claims. Data from a sample of over 2,000 adolescents attending junior and senior high schools in a western Canadian city were analysed to determine the independent and contextual effects of self-control and strain on involvement in delinquent behaviour. Results suggest that both self-control and strain are important contributors to delinquency, but in an additive and not an interactive way. Such results do not seem to provide support for claims made by control theorists, who would no doubt argue that the effects of strain should be conditioned by low self-control.
Like so much of the discussion around gun control during the last 40 years in Canada, the recent debate over the gun registry has been plagued by misinformation, misrepresentations, and some rather outlandish claims. The discussion might be returned to a more reasonable footing if some of these could be put to rest, but I doubt it; support for and opposition to gun control has tended to be based on strongly held convictions rather than on solid evidence, and that is unlikely to change in the foreseeable future. Nevertheless, it can do no harm to at least try to sort out myths from facts in this highly contentious policy arena. One such myth is that having a gun registry is something new for Canada. In fact, Canada has had a gun registry for years (since the 1930s), although for most of that time only handguns and certain other "restricted" firearms (including some long guns) have required registration. (1) However, not even the attempt to register all "ordinary" long guns (hunting rifles and shotguns) is new here; a 1940 amendment to the Defence of Canada Regulations required all such guns to be registered with the RCMP. (2) It remained in force until the war ended in 1945. What is new about the 1995 legislative requirements, then, is not the creation of a gun registry but the requirement, for the first time in peacetime in Canada, for all long guns to be registered. Of course, it is difficult to draw from the experience of universal registration of firearms during wartime any persuasive conclusions about the likely effectiveness of such registration in preventing or reducing firearms abuses 50 years later in peacetime. (3) The issue, however, is not whether we should retain a gun registry but whether we should require registration of ordinary long guns rather than just requiring long gun owners to be licensed, as was the case prior to 1996. One of the reasons advanced for universal long gun registration has been that it will help police in investigating crimes and in taking precautions when responding, for instance, to domestic violence, hostage-taking, or other "gun calls'(see Canada, Department of Justice 1994: 14). In support of this rationale, proponents of long gun registration have recently begun to cite statistics concerning the number of times the police have requested information from the new registry. (4) These statistics are not, by themselves, very informative, however, since we have not been told (a) how frequently the police made such requests before long guns were included in the registry, (b) what proportion of current police requests concern long guns rather than other kinds of firearms that are required to be registered, or (c) what proportion of them concerned gun registration as opposed to gun owner licensing information, also included in the registry. (5) We would need all three pieces of information before we could draw any conclusions about how much more helpful, if at all, the registry has become to the police as a result of the introduction of registration of long guns. In this regard, Toronto Police Chief Julian Fantino's recent assertion that the registry has proved to be of no significant additional assistance to his police service (one of the largest in the country) in investigating firearms-related crimes should perhaps not be lightly dismissed as simply the aberrant opinion of one police chief. (6) Indeed, it is very doubtful whether even the requirement for handgun registration as such (as opposed to the requirement for those who own or possess handguns to obtain permits or licences) has ever had much impact on handgun use in crime or on any other kind of handgun abuse, although there is no clear Canadian evidence on this. The focus on crime prevention and reduction as the principal justification for universal registration of "ordinary" long guns, however, is one of the more inexplicable quirks of the gun control debate, since, by any criteria that I can think of, long gun use in crime is not by any means the most serious of the problems that controls on long gun possession should be designed to address. …
This article examines parents in the youth justice system, based on a conceptual analysis and a phenomenological inquiry of parents with a son convicted of crimes in the youth justice system of a district in Western Canada. The difficult task of parenting a young offender is made more onerous by the societal tendency to blame parents or ignore their need for support; yet policies and practices expect parents to be the primary sources of supervision, care, and rehabilitation of youth in difficulty. The findings chronicle parental experiences of stress and loss and the hard work parents do to respond to the difficult and contradictory expectations of the youth justice system. Even when they did "all the right things" parents encountered systemic injustices and exclusion from meaningful participation in important decisions that affected their sons and themselves. The discussion explores implications, taking parental experiences into account, and proposes systemic changes, based on a community change approach to youth justice, to facilitate enhanced parental support and empowerment.
The published Canadian homicide rate indicates a steady downward trend since the mid-1970s. Yet the conventional homicide rate inaccurately reflects the nature of homicide, when used as a social barometer, and should be supplemented with a new homicide rate, calculated using available demographic information about offender characteristics. This paper uses recent advances in statistical techniques to show that an age-adjusted homicide rate exhibits a significantly different trend than that of the conventional rate: (1) there was no structural break in the trend until the late 1980s; (2) until the early 1990s the trend was an increasing homicide rate; and (3) although the homicide rate has been decreasing since the mid-1990s, there is insufficient statistical evidence to suggest a new downward trend. These findings suggest that. demographics and time series analysis are required to properly assess homicide trends, helping to isolate social variables so their effects on homicide rates can be more accurately determined. Homicide rates have a substantial affect on social policy and public opinion and therefore should be critically calculated. Finally, this paper demonstrates the benefits of cooperation between academic disciplines and the utility of taking advantage of the latest theoretical and empirical techniques to reach a better understanding of social phenomena.
After motor vehicles, firearms are the leading instruments of injury-related death in North America (Chapdelaine, Samson, Kimberley, and Viau 1991; National Center for Health Statistics 2000). Each year in Canada, there are more than 1,000 firearm homicides, suicides, and unintentional fatalities and about 10 times as many non-fatal, but often debilitating, injuries resulting from the misuse of firearms (Hung 2000). Those dying of gunshot wounds, especially homicide and unintentional death victims, are disproportionately drawn from the more youthful segment of the population. For example, more than half of all fatalities in Canada resulting from firearm accidents involve persons under the age of 25 (Chapdelaine et al. 1991). Firearms are far more lethal than other means of attack (e.g., knives, clubs, or fists), and they are the method most likely to succeed in suicide attempts (Gabor 1994). Rigorous studies have shown that the presence of firearms in the home elevates the risk that an occupant will be a victim of a gun homicide or suicide, when previous violence and other risk factors are held constant (Kellermann, Rivara, Rushforth, Banton, Reay, Francisco, Locci, Prodzinski, Hackman, and Somes 1993; Brent, Perper, Allman, Moritz, Wartella, and Zelenak 1991). These facts are consistent with an opportunity model of crime and suicide and should be sufficient to place firearms on any list of hazardous consumer products. Firearms are designed to kill, and they do so more efficiently than other consumer products. As such, it appears eminently reasonable to regulate their distribution and promote owner accountability. But should firearms also be the subject of a national effort to record the ownership and specifications of every gun owned in Canada? Complicating factors and impediments to universal registration As with any consumer product, and even the national census, one is dealing with a moving target, as the volume of the various categories of firearms is constantly shifting and, hence, requires continual readjustment. Also, firearms are geographically mobile products: people tend to take their firearms with them when they move. A comprehensive registration system must therefore track firearms as they are transported within Canada and across our national borders. There is also a growing illicit trade in firearms (Firearms Smuggling Working Group 1995), especially handguns, and an increasing number of handguns are being used in homicides and other violent crimes (Dauvergne 2002). Further complicating the development of a complete firearms registry is the fact that, unlike the decennial census and motor vehicle registration, maintaining a count of firearms and a record of their ownership is meeting with a fair amount of resistance. A significant number of gun owners have as yet failed to comply with the licensing and registration requirements established when Bill C-68 was enacted in 1995. As of 30 June 2003, the Canadian Firearms Centre reported that about 200,000 of an estimated 2.3 million gun owners did not have a valid license and about 1.6 million of an estimated 7.9 million long guns were not registered (Leblanc 2003). The resistance ranges from the passive--simply failing to comply with the licensing and registration requirements--to concerted efforts, spearheaded by certain firearm interest groups, to sabotage the system by registering en masse just before the deadline or by making deliberate errors on relevant forms in order to invalidate the system (Walton and Galloway 2002). Equally serious has been the decision of six provinces not to enforce violations of the registration provisions and the court challenge by several provinces based on the argument that the registry constitutes an encroachment upon provincial property rights (Lunman 2003). While surveys at the time Bill C-68 was tabled indicated that public support for a national registry of all firearms was strong, the lack of buy-in by more than half the provinces and from many gun owners (especially from the west and far north) creates a major public policy dilemma. …
Cet article porte sur l' utilisation, par les policiers, d'un pouvoir que leur a conféré le Code criminel canadien en 1994: celui de remettre les suspects en liberté sous conditions en attendant leur première comparution (art. 499 [2] et 503 [2.1]). Nous avons mené une recherche portant sur l' usage de cette pratique dans le cas de ceux suspectés dans un événement de violence conjugale. Des entrevues semi-dirigées ont été conduites auprès de 18 policiers (enquêteurs et lieutenants-détectives) du Service de police de la Ville de Montréal, entre les mois de mars et octobre 2000. Les enquêteurs rapportent que ce nouveau pouvoir leur a permis de libérer une proportion importante de prévenus. Toutefois, l' ampleur de cette pratique varie entre les enquêteurs, qui disent utiliser cette mesure pour 35 % à 90 % des prévenus. Cette décision est prise si l' enquêteur détermine que le prévenu ne risque pas de récidiver. Les facteurs les plus déterminants dans la décision que les enquêteurs doivent prendre sur le statut des prévenus sont la présence ou non d'antécédents de violence (judiciarisés ou non) ou de bris d'ordonnance ainsi que la gravité de l'accusation. La condition de remise en liberté qu'ils considèrent la plus importante et qu'ils imposent presque systématiquement est celle sur la non-communication avec la victime.
For decades, firearm regulation has been a source of spirited debate in Western countries, particularly in North America. However, the enactment in Canada in 1995 of the Firearms Act, which, among other things, called for the establishment of a registration system for all lawfully owned firearms, has polarized Canadians like few other justice issues. The rifts between several provinces and the federal government, between western and eastern Canadians, and between urban and rural dwellers have been amplified by this legislation. Until December 2002, the debate as to the merits of the registry was largely a partisan one involving little more than hypothetical scenarios and anecdotal evidence. Rigorous, non-partisan research as to the registry's impact upon public safety is, as yet, unavailable. However, the release of the Auditor General's Report near the end of 2002 constituted the first significant, independent assessment of the registry, and its revelations about serious cost overruns dealt a severe blow to the program. The Auditor General's highly critical report reignited debate as to the cost effectiveness of the registry and lent credibility to opponents of the program, who have lamented its costs and its perceived intrusion upon personal liberties. The Auditor General's report has precipitated some changes in the administration of the program that will, among other things, ensure that it will operate more transparently. In addition, there is added pressure to study its impact on public safety. The three contributions that follow constitute the reflections of three academics who have written about firearms-related issues before. The opinions expressed reflect the diversity of views on the issue of universal registration. Any conclusions at this point are necessarily tentative, as the deadlines for registering firearms and the associated amnesties have only recently passed. The first contribution, by Neil Boyd of Simon Fraser University, notes that the decline in firearm-related mortality in Canada has coincided with regulatory changes beginning in the late 1970s and culminating in the enactment of Bill C-68 in 1995. While Boyd is careful not to make too much of this association between regulation and mortality, he argues that the increasing regulation of firearms reflects cultural change; specifically, a growing intolerance on the part of Canadians for firearms and their associated perils. The apparent trend of declining gun ownership is, according to Boyd, a reflection of this cultural change. Fewer firearms, in turn, result in fewer fatalities. Boyd claims that the registry is beneficial to public safety and suggests that the intense criticism of the program's cost is due not to its lack of impact or to poor management, but to unusual scrutiny as a result of its highly politicized nature. In addition, he asserts that some of the costs have been incurred as a result of legal challenges by the registry's opponents, as well as an aggressive campaign of non-compliance and even sabotage by some gun owners. The second contributor, Philip Stenning, formerly of the University of Toronto and currently at Victoria University of Wellington, New Zealand, is less sanguine about universal registration. Stenning begins by reminding us that the registration of firearms is nothing new in Canada. Handguns have been registered since the 1930s, and even long guns were subject to registration during World War II. He notes, however, that despite Canada's experience with registration, evidence is lacking as to its merits. Notwithstanding the lack of evaluation, proponents of long gun registration have recently pointed to the number of requests law enforcement agencies have made of the registry. Stenning argues, however, that baseline data on the volume of such requests prior to the registration of long guns are not available and that these requests might concern matters other than registration. …
This paper examines the criminal technologies and criminal organization associated with gambling-related computer crimes that occurred in the video lottery terminal industry in the province of Nova Scotia. We emphasize the techniques of VLT crime, such as cracking protection codes, boot tracing, ghost programming and down-lining, as rationally geared to neutralizing social control. We analyze how the cyber-attacks were socially organized and we conclude by discussing the implications that our case study has for the field of computer crime.
For much of past two years, advocates of firearm licensing and registration have been attacked by hunters, gun lobbyists, and others concerned about soaring government costs of federal program. And in December 2002 Auditor General, Sheila Fraser, released a report that was sharply critical of these increased costs. Dubbed the billion-dollar registry by its opponents, it has been quite fairly estimated that program will have cost more than $1 billion by 2005, 10 years after its inception (Mauser 2001). What has typically escaped notice, however, is that Auditor General Fraser was not prepared to make any statements about effectiveness of program in her December 2002 report, noting, did not audit program efficiency or whether it is meeting its objectives (Canada, Department of Justice 2002: para. 10.21). It is task of Auditor General to point to budgetary anomalies, not to examine relative efficacy of government programs. The rate of firearm death in Canada Between 1989 and 1999 rate of firearm death in Canada dropped from 5.0 per 100,000 to 3.3 per 100,000; this figure included not only declines in culpable homicide but also declines in accidents and suicides. Changes to firearm regulation, beginning in 1978 and culminating in 1995 approval of Canadian Firearms Program, predate these declines. Admittedly, however, it is very difficult to determine whether there is a cause-effect relationship between legislative and regulatory changes and incidence of firearms deaths in Canada. We have only a correlation, and, as critics note, most of decline in firearms deaths occurred prior to 1995, date of implementation of Canadian Firearms Program. With cases of firearms homicides, we also have to acknowledge demographic shift resulting from baby boom generation passing into middle age in both Canada and United States: there are fewer young men in population, and there is, correspondingly, less culpable homicide of all kinds in both countries. But a demographic shift alone cannot explain dramatic decrease in all firearms deaths between 1989 and 1999. For example, significant declines in suicides with firearms cannot be linked to life cycles of baby boomers; suicides are most commonly carried out by elderly men, a demographic grouping rarely associated with culpable homicides involving firearms. It is probably more appropriate to think of decline in rate of firearm death as a reflection of cultural change, rather than as a direct consequence of one specific law. We are becoming a culture less tolerant of guns, images of violence that they tend to represent, and damage that they can do; we are increasingly aware of harms that they are associated with and understandably eager to place limits upon their presence in our daily lives. The changing law has served as a catalyst for, and as a reflection of, these sympathies. We license and register cars; many gun owners can understand corresponding logic. If society requires a licence to operate a vehicle, and appropriate registration of each vehicle, why should a gun, another potentially dangerous commodity, be any different? In fact, as of close of 2002, more than 70% of gun owners had registered their weapons; among majority of non-gun-owners, there is overwhelmIng public support for both licensing and registration (Canada NewsWire 2002). Moreover, in support of this hypothesis of cultural shift, there is evidence that rates of gun ownership have been declining in Canada during 1990s (GPC Research 2001). There is also evidence within Canada of a relationship between extent of gun ownership and extent of firearms deaths: provinces with higher rates of firearm ownership are statistically more likely to have higher rates of firearm death. Two specific areas of concern have emerged from criticisms of licensing and registration: (a) extent of benefits that we collectively realize from Canadian Firearms Program and (b) thorny issue of increased costs and future expenses. …
The starting point for this study is the finding that people who have to wait for their statutory release date to be paroled are considered by the National Parole Board to pose such a high level of risk that they cannot be released any earlier. Yet the facts show that many of them make a success of their statutory release. Indeed, 10 years after their release, a number of individuals remain outside the Canadian penitentiary system, So how can we identify these individuals and ensure that they are no longer considered as posing an undue risk and can be paroled before their sentence expires? The author draws on two data sources to answer the question: (1) the Correctional Service of Canada's Offender Management System, and (2) interviews with offenders who have made a success of their statutory release.
This paper uses nine years of youth court data to understand two different trends: increases in the proportion of youth court cases (found guilty) involving girls and few changes in the rate of finding girls guilty in youth court. It appears that the increased proportion of cases involving girls (found guilty) is due more to a decrease in the rate of finding boys guilty than to an increase in finding girls guilty. Thus, in understanding trends in the use of youth court, explanations should explore why it is that the rates for girls are relatively stable whereas the rates for boys, for property offences in particular, are decreasing. An explanation that assumes that rates of offending (or apprehension, or imposition of guilty findings) are increasing for girls will not, we suggest, fit the existing data.
The high rates of Aboriginal admissions to custody have been noted by Commissions of Inquiry, all levels of government, and Corrections texts in Canada for some time. In the most recent year for which data are available (2000–2001), Aboriginal offenders accounted for 19% of provincial admissions and 17% of federal admissions to custody. This article examines provincial custodial sentenced admissions for Aboriginal and non-Aboriginal offenders since 1978, when national statistics including the ethnicity of the offender were first published. Particular emphasis is paid in this analysis to recent trends during a period in which Parliament and the Supreme Court have tried to address the problem, the former by statutory recognition of the unique nature of Aboriginal offenders, the latter by judgments interpreting Criminal Code sentencing provisions introduced in 1996. The findings suggest that little progress has been made in reducing the number of Aboriginal sentenced admissions over the past few decades. Although the volume of Aboriginal admissions to custody has declined since 1993–1994, non-Aboriginal admissions have declined at an even faster rate, suggesting that specific policy changes are not responsible for the Aboriginal decline.
L' étude vise à comparer des délinquants sexuels qui affirment avoir été abusés sexuellement dans le passé (n = 137) avec des délinquants sexuels qui ne rapportent aucune victimisation sexuelle (n = 141). Les résultats montrent que les délinquants-victimes sont plus nombreux à avoir été exposés à des modéles familiaux inadéquats, à avoir manifesté certains troubles du comportement avant l'âge de 18 ans et à avoir des antécédents judiciaires pour des crimes sexuels. Ils ont également connu une vie sexuelle plus précoce et se considèrent moins compétents sur le plan sexuel que les délinquants-non victimes. Malgré les différences observées entre les deux groupes de délinquants sexuels, des analyses de covariance révèlent que les troubles du comportement et le développement sexuel sont davantage influencés par l' exposition à des modèles familiaux inadéquats que par la victimisation sexuelle. De plus, qu'ils aient été victimes ou non, les délinquants sexuels de notre étude présentent plusieurs points en commun. Ces similitudes semblent d'ailleurs jouer un rôle plus important que la victimisation sexuelle dans le développement de la délinquance sexuelle et, par conséquent, méritent plus d'attention des chercheurs et des cliniciens.
This study investigates whether or not people see young offenders as a distinct group of youths who reject society's punishment norms. Specifically, views from members of the public and from young offenders on appropriate punishments in three hypothetical cases are explored. Results reveal that not only do members of the public see young offenders as a distinct group of youths who prefer more lenient punishments than do other adolescents, but young offenders themselves also believe that other young offenders would prefer lenient punishments. Young offenders, however, actually suggest harsher punishments than members of the public suggest. Moreover, young offenders are aware of public support for punitive sanctions and of the desire to keep offenders out of the community through incarceration. These findings support earlier findings by Benaquisto and Freed (1996) that offenders do not reject society's punishment norms. Young offenders' misperception that the public is punitive, however, may present a challenge for reintegration.
This paper explores the relative contributions of four ecological theories of crime - urbanization theory, social disorganization theory, opportunity theory, and the overload hypothesis - to understanding crime rates and the use of discretion by Canadian police in their decision making about youth. Data on crime rates and police charging practices in 447 communities in Canada in 1991 were regressed on indicators of the characteristics of the police force and the community, within a path analytic framework. Support was found only for social disorganization theory as an explanation of crime rates; and for both urbanization theory and social disorganization theories as explanations of the police use of discretion with youth. No support was found for opportunity theory or the overload hypothesis.
In both the United States and Canada, a community protection approach to the perceived enduring dangerousness of sex offenders has emerged since the 1980s, in response to several high profile cases involving the sexual assault and murder or mutilation of young children. The key elements in this community protection approach are sex offender registration and tracking, community notification, and post-sentence controls in the form of civil commitment, peace bonds, and community surveillance. This paper compares the different trajectories community protection has taken in the United States and in Canada and offers an explanation for the relatively slower and more cautious approach taken by the Canadian federal government, compared to the rapid, aggressive approach taken in the United States at both a federal and state level.
Empirical research has shown that familial disruption is associated with delinquent behaviour. Recent investigations suggest that reduced levels of attachment in non-traditional families may be responsible for this effect. However, it is not known whether the impact of familial disruption varies according to familial socio-economic status (SES) or the gender of the children. Some authors have argued that the criminogenic influence is greater for boys, while others have maintained that girls are more adversely influenced. Similar contradictory evidence has been reported with respect to SES. Finally, a substantial number of studies have shown that the influence of familial disruption is largely invariant to gender and SES. The goal of this study was to determine whether or not familial disruption interacts with these two variables. Multivariate logistic regression was used in the investigation. A representative sample of Ontario school children was analysed (N = 1,891). The analysis reveals that family structure interacts with SES, but only with respect to one form of delinquent behaviour. This result may represent a chance finding. Overall, the relationship between family structure and delinquency is remarkably similar across circumstances.
It has often been recognized that Quebec has a different approach to youth justice from that which exists in the rest of Canada. The largest difference, however, appears to be in the rate of bringing cases into youth court. Once a case arrives in youth court, inter-provincial variation in the manner in which the case is handled diminishes. When asked,judges in Quebec are more likely than judges in other provinces to report that youths benefit from the youth court experience and that few cases could be dealt with adequately outside of the youth justice system. However these differences appear to be accounted for by the perceived adequacy of the administration of the Young Offenders Act and not by more basic differences in the penal philosophies of the two sets of judges. It is well known that there is variation across provinces in the administration of the Young Offenders Act (Carrington 1999; Doob and Sprott 1996). More specifically, it has often been recognized that Quebec has a different approach to youth justice. In the context of the debates around the Youth Criminal Justice Act (YCJA), it has often been asserted that Quebec is "different" and has a "more effective" youth justice system than other provinces, and that judicial approaches to youth crime are dramatically different in Quebec.
This paper provides a description and evaluation of the Toronto 'John School' Diversion Program. This alternative sentencing strategy is designed for the male clients of female prostitutes who have been charged with an offence under Section 213 of the Criminal Code. Upon entering a guilty plea, these men are diverted into a one-day educational program that focusses on the social harms caused by the sex trade. After completing the program, the original prostitution charge is withdrawn. Results from a pre- and post-program survey of John School participants (N=366) indicate that the program is somewhat successful in achieving some of its principal objectives. After attending the program, participants are more likely to accept responsibility for their actions, more likely to admit that they might have a sex addiction and are less likely to report favourable attitudes towards prostitution. There is also evidence of significant post-program improvement in the respondents' knowledge of Canadian prostitution law and an increased awareness of both the victims and dangers associated with the sex trade. After completing the program, the vast majority of John School participants indicate that they will never again attempt to purchase sexual services from a prostitute. However one out of every ten participants indicates that he will continue to use prostitutes in the future. The paper concludes with a discussion of the potential benefits and problems associated with the John School model.
Using rational choice theory, the authors compared the characteristics of the actions of 16 borderline violent offenders and those of 18 narcissistic violent offenders. The results of the analyses of all phases of their violent acting out show marked differences between the two groups. In fact, the borderline violent offenders, compared to the narcissistic offenders, are more likely to have negative emotions and to encounter more problems of loneliness, lower self esteem, financial problems and difficulties with psychoactive drug intoxication. They also appear to be more driven by sexual appetite or emotions or by the need to renew with loved ones or avoid separation from loved ones; they use physical violence more often during robberies. On the other hand, the narcissistic offenders are more prone to accept "contract" killing for a criminal organization. They seek out power or status; they try to eliminate competitors during their criminal activities. The narcissistic offenders will deny using violence while borderline offenders will explain it away by their loss of control. As well, the narcissistic offenders are more likely to resist arrest.