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Trauma Among Lesbians and Bisexual Girls in the Juvenile Justice System
Juliette Noel Graziano and Eric F. Wagner Traumatology 2011 17: 45 originally published online 10 January 2011 DOI: 10.1177/1534765610391817 The online version of this article can be found at: http://tmt.sagepub.com/content/17/2/45 Published by:
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Trauma Among Lesbians and Bisexual Girls in the Juvenile Justice System
Juliette Noel Graziano1 and Eric F. Wagner1

Traumatology 17(2) 4555 The Author(s) 2011 Reprints and permission: http://www. sagepub.com/journalsPermissions.nav DOI: 10.1177/1534765610391817 http://tmt.sagepub.com

Abstract Lesbian, gay, bisexual, transgender, queer, and/or questioning (LGBTQ) youth are at particularly pronounced risk for experiencing trauma, and trauma appears to increase the risk for juvenile justice system involvement. While it is well documented that LGBTQ youth experience significantly higher rates of trauma and sexual orientation violence than do their heterosexual counterparts, the interconnectedness of trauma, delinquency, and sexual-minority status among teenage girls has not been well studied. In addition, the juvenile justice system is ill equipped to deal with LGBTQ youth, underequipped for addressing issues related to trauma, and may inflict further trauma through homophobia among staff and sexual majority peers. Given (a) the pronounced trauma-related treatment need among juvenile offending girls, and (b) the lack of research focused on sexual-minority girls in the justice system, this review will focus on recent trauma research involving juvenile justice system-involved and lesbian and bisexual girls. The authors review current trends and practices and make recommendations for how to improve services and treatment for justice system-involved girls. Keywords trauma, lesbian, bisexual, girls, juvenile justice system

A large research literature has found that experiencing trauma related to sexual or physical abuse is linked to a host of negative psychological, behavioral, and health-related outcomes among adolescents and adults (Breslau, Davis, Andreski, & Peterson, 1991; Briere & Runtz, 1993; Dembo, Williams, & Schmeidler, 1993; Giaconia et al., 2000; Mullen, Martin, Anderson, Romans, & Herbison, 1996; Neumann, Houskamp, Pollock, & Briere, 1996; Ritter, Stewart, Bernet, Coe, & Brown, 2002; Widom, 1995). While there seems to be a particularly strong relationship between trauma, operationalized as either posttraumatic stress disorder (PTSD) or subsyndromal symptoms of traumatic stress, and delinquency, especially among girls, this topic has only recently received attention (Simkins & Katz, 2002; Smith, Leve, & Chamberlain, 2006; Widom, 1995). Criminological theories have historically focused on men rather than on women, and little attention has been devoted to gender-specific variables that may predict and explain female offending. To this end, feminist researchers argue that there are important gender differences regarding pathways into the justice system, including a particularly strong linkage between girls experiences of trauma related to physical or sexual abuse and subsequent offending behavior (Bloom et al., 2005). Since characteristic female responses to such types of trauma (e.g., running away from home, acting out, aggression, etc.) are often viewed as symptoms of conduct disorder or problematic antisocial behavior, and thus are criminalized, traumatized girls become

entangled in the justice system without adequate attention to gender-specific needs such as trauma-focused treatment (Chesney-Lind & Shelden, 2004; Simkins & Katz, 2004). Sexual abuse, physical abuse, traumatic stress, and PTSD are much more likely to be reported by youth with juvenile justice system involvement than by youth without justice system involvement (Acoca & Dedel, 1998; Cauffman, Feldman, Waterman, & Steiner, 1998). While the prevalence of traumatic stress and PTSD among juvenile justice populations (primarily male) has been estimated to be at least 8 times greater than found in adolescent community samples (Wolpaw & Ford, 2004), research shows that the prevalence of trauma-related stress and diagnoses among female juvenile justice populations is more than 200 times the national average (Smith et al., 2006). Moreover, histories of physical and sexual abuse are significantly more prevalent among juvenile offender girls than among juvenile offender boys (McCabe, Lansing, Garland, & Hough, 2002). Since trauma-related stress, PTSD, physical abuse, and sexual abuse are especially associated with delinquency for girls,

Florida International University

Corresponding Author: Juliette Noel Graziano, University Park Campus, MARC Suite 310, 11200 SW 8th Street, Miami, FL 33199 Email: juliette321@yahoo.com

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46 research concerning risk factors for abuse (and subsequent trauma) and delinquency among girls is a priority. An adolescent subpopulation at particularly high risk for experiencing trauma are lesbian, gay, bisexual, transgender, queer, and/or questioning (LGBTQ) youth. While it is well documented that LGBTQ youth experience significantly higher rates of trauma and sexual orientation violence than do their heterosexual counterparts (Rivers & DAugelli, 2001; Saewyc et al., 2006; Savin-Williams, 1994), the interconnectedness of trauma, delinquency, and sexual-minority status among teenage girls has not been well studied. There has been a general increase in research concerning the health and wellbeing of LGBTQ youth; however, there remains a dearth of research specifically focused on PTSD rates. DAugelli, Grossman, and Starks (2006) did include a measure of PTSD in their study of LGBTQ adolescents and found that 9% of the lesbians, gay, and bisexual youth met criteria for a PTSD diagnosis. Three times the number of girls reported PTSD compared to boys, and PTSD was also significantly associated with gender atypical behavior and physical sexual orientation violence. This is in line with previous studies that show in community samples girls are 2 times more likely than boys to develop PTSD after being exposed to trauma (Breslau et al., 1998). Juvenile offender girls as a group report high rates of trauma, and LGBTQ youth may be at particular risk for experiencing sexual orientation violence, gender atypicality trauma, family rejection, stigmatization, and peer victimization (Berlan, Corliss, Field, Goodman, & Austin, 2010; Birkett, Espelage, & Koenig, 2009; Davis, Saltzburg, & Locke, 2009; Kosciw, Greytak, & Diaz, 2009). Since sexualminority youth are at an elevated risk for trauma, and girls are more prone to meet criteria for PTSD than are boys, the link between trauma and delinquency among lesbians and bisexual girls warrants investigation. Delinquency during adolescence can have serious longterm negative consequences for physical and mental health and places girls at risk of future arrests, reduced educational and employment opportunities, domestic violence, and dysfunctional parenting (Bardone et al., 1998; Bushway & Reuter, 2002; Clingempeel, Britt, & Henggeler, 2008; Dembo et al., 2000; Giordano, Milhollin, Cernkovich, Pugh, & Rudolph, 1999; Piquero, Daigle, Gibson, Leeper, & Tibbetts, 2007; Serbin, Peters, McAffer, & Schwartzman, 1991; Sweeten, 2006). Given (a) the lack of research focused on sexual-minority women in the justice system, and (b) the pronounced trauma-related treatment need among juvenile offending girls, this review will focus on recent trauma research involving juvenile justice systeminvolved lesbians and bisexual girls. The goals of our review are to identify strengths and weaknesses of current approaches to female juvenile offenders and provide guidance for how services for juvenile offending girls may be improved.

Traumatology 17(2)

Background Definitions of Trauma and PTSD

Current definitions of what constitutes trauma and the necessary and sufficient criteria for a diagnosis of PTSD differ regarding the initial stressor needed for a PTSD diagnosis, symptom onset, and duration among those diagnosed with PTSD, and the functional impact of PTSD. According to the Diagnostic and Statistical Manual of Mental Disorders, 4th ed. (DSM-IV; American Psychiatric Association [APA], 1994), a stressor signifies a traumatic event when the person has experienced, witnessed, or was confronted with an event or events that involved actual or threatened death or serious injury, or a threat to the physical integrity of self or others (p. 427). In addition, the response of the person includes intense fear, helplessness, or horror (p. 428). The DSM-IV notes that the response in children may differ and be expressed instead by disorganized or agitated behavior (p. 428). In addition, the person must exhibit a variety of symptoms, for a specified duration, with compromised functioning. According to the World Health Organizations (WHO) International Classification of Diseases (ICD-10) PTSD is a response to a stressful event or situation of an exceptionally threatening or catastrophic nature, which is likely to cause pervasive distress in almost anyone (WHO, 2007, Section F43.1). Predisposing factors, typical symptoms, and the onset time frame are outlined, and the diagnosis requires evidence of symptom arousal within 6 months of the event. Abram et al. (2004) argued that the definition of trauma by the DSM-IV is somewhat ambiguous, and there are scant reliability and validity studies of PTSD measures based on the DSM-IV criteria. They argue that there remains a lack of consistent measures of trauma, and the most utilized instruments measure different types of trauma. For example, violent victimization, sexual victimization, and/or family victimization may be measured differently or not at all, depending on the specific assessment instrument. This state of affairs ultimately reduces reliability and validity and muddies the waters regarding what is the most appropriate way to conceptualize trauma and its impact. PTSD clinical researchers argue in favor of a consensually understood and empirically validated framework to define and measure traumatic events (p. 408). That said, such a framework would include narrowing the focus and specifically naming the different types of trauma being investigated for research endeavors that explore trauma and its impact. While important advances have been made regarding the diagnosis of trauma and its impact, notable discrepancies remain (Peters, Slade, & Andrews, 1999), which could have serious implications for populations that have suffered from trauma, such as not meeting criteria for receiving services.

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Graziano and Wagner

47 juvenile offenders and lesbian or bisexual exhibit two risk factors known to be positively associated with trauma and PTSD, it may be that the combination of these two risk factors compound risk additively or multiplicatively. However, the absence of empirical research on this topic leaves unknown the issue of how juvenile offending and lesbianism or bisexuality may interact in regard to risk for trauma and PTSD. While at this time it is unknown how many lesbians and bisexual girls are involved in the juvenile justice system, a handful of studies have included a measure of sexual orientation and can provide some insight. For example, Belknap and Holsinger (2006) studied 444 female and male incarcerated youth and found that sexual identity was an important variable in offending behavior. Twenty-two percent of incarcerated youth self-identified as bisexual and 5% self-identified as lesbian/gay. Girls, however, were 6 times as likely to identify as bisexual than boys and 3 times as likely to identify as homosexual compared to boys. The authors acknowledge they could not discern whether boys are less likely to report gay or bisexual identities or if it is an identity that places girls, but not boys, at increased risk of marginalization and delinquency (p. 55). In a study that included more than 2,000 youth in detention facilities conducted by Ceres Policy Institute found that 13% of the youth in their sample were LGBTQ, where 11% of the boys and 23% of the girls were not straight (Irvine in Majd et al., 2009). In a study that focused on girls only, Schaffner (1999) interviewed and reviewed files of more than 100 justice systeminvolved young women and reported that between one fifth and one third of the sample were bisexual or lesbian. The consensus among researchers and clinicians working in juvenile offending is that minority sexual orientation is especially overrepresented among female delinquents. This lack of specific information regarding the prevalence of lesbians and bisexual girls severely limits our understanding of their specific risk factors and needs. Research has documented the prevalence of and specific issues related to abuse, trauma, and PTSD among justice system involved girls as well as community samples of lesbians and bisexual girls. In addition, qualitative research has started to focus on the experiences of LGBTQ in the juvenile justice system, and collectively, these sources can provide insight regarding the trauma-related treatment needs of lesbians and bisexual girls in the justice system.

Types of Trauma
Trauma is a risk factor for delinquency and a host of other emotional, physical, and health-risk problems (ChesneyLind 1989; Gover, 2004; Jaffee, Caspi, Moffitt, & Taylor, 2004; Perez, 2000; Robertson, Baird-Thomas, St. Lawrence, & Pack, 2005; Simkins & Katz, 2002; Smith et al., 2006; Zierler et al., 1991). There are numerous forms of trauma, which include interpersonal violence (sexual abuse, physical abuse, and domestic violence) and/or the witnessing of interpersonal violence. In addition, neglect, the loss of a loved one, serious accidents, terrorism, natural disasters, and wars and other forms of political violence are often traumatic for the individual experiencing them. Natural disasters, political violence, the loss of a loved one, and serious accidents can be extremely traumatic. However, there is no reason to believe lesbian and bisexual girls are disproportionately affected by such trauma. In contrast, the association between child abuse and victimization and delinquency has been well established, and, in fact, as Steiner, Garcia, and Matthews (1997) found among violent youth in California who met criteria for PTSD, none of them reported the recent natural disasters in California, which some of them lived through and most of them heard about and saw on television (Loma Prieta earthquakes, Oakland firestorm, Rodney King riots) as traumatic events (p. 361). Instead they reported interpersonal violence in the family, including abuse, injury, and murder. Since interpersonal violence seems to be the type of trauma most strongly and directly linked to juvenile offending, this review will focus on the trauma that ensues after interpersonal violence (i.e., physical abuse, sexual abuse, and sexual orientation violence). Moreover, in addition to reporting higher rates of sexual abuse and physical punishment, girls also report experiencing violence, in comparison to boys who more frequently report witnessing violence (Abram et al., 2004; Ford, Chapman, Hawke, & Albert, 2007; Hennessey et al., 2004).

Trauma and PTSD Among Lesbians and Bisexual Girls Involved in the Justice System Prevalence of Trauma and PTSD
We conducted an exhaustive literature search and found not a single publication that addresses the prevalence of trauma and PTSD among girls who are both (a) juvenile justice system involved, and (b) lesbian or bisexual. While the empirical literature has documented higher rates of trauma and PTSD among juvenile justice systeminvolved girls (compared to girls not involved in the juvenile justice system) as well as higher rates of trauma and PTSD among lesbian or bisexual girls (compared to heterosexual girls), the combination has not been examined. Since girls who are both

Trauma Among Justice SystemInvolved Girls Prevalence of Abuse, Trauma, and PTSD
Estimates of the prevalence of abuse, trauma, and PTSD vary depending on the types of abuse or trauma under review; instruments used to detect abuse, trauma, or PTSD; and the segment of the justice population investigated (Teplin,

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48 Abran, McClelland, Dulcan, & Mericle, 2002), though in general, offending youth typically report much higher rates of physical and sexual abuse, trauma, and PTSD than do youth not involved in the juvenile justice system (Abram et al., 2004). Having been abused places youth at increased risk for violent behavior and arrests, and among juvenile justice system populations is associated with an earlier age of first offense and a greater number of total offenses (Smith et al., 2006; Widom & Maxfield, 2001) These associations appear to be particularly strong among justice systeminvolved girls. Belknap and Holsinger (2006), Brosky and Lally (2004), and Dembo, Williams, Wothke, Schmeidler, and Brown (1992) all documented significantly higher rates of sexual and physical abuse among delinquent girls than among delinquent boys, which range from 28% to 60% of girls reporting sexual abuse and 38% to 75% reporting physical abuse. Cauffman et al. (1998), Ford et al. (2007), and Mueser and Taub (2008) all documented significantly higher rates of PTSD among justice systeminvolved girls than among justice systeminvolved boys, with more than 40% of girls reporting PTSD. According to Cauffman, these rates are 50% higher than the rate typically reported by male juvenile delinquents. Studies focused exclusively on juvenile offending girls have confirmed that they are especially likely to report physical abuse, sexual abuse, and trauma related to abuse experiences (Acoca & Dedel, 1998; Simkins & Katz, 2002). Moreover, abuse appears to be a stronger predictor of offending behavior for women than for men, with female abused youth 7 times more likely to be arrested than their nonabused, same-sex counterparts (Makarios, 2007). It should be noted that epidemiological research has found differences between childhood sexual and physical abuse in the areas of age, race/ethnicity, gender, and relationship between perpetrator and victim, which has important clinical implications (Jason, Williams, Burton, & Rochat, 1982). Likewise, type of abuse may be linked to different behaviors and outcomes. For example, in studies that compared sexual and physical abuse, somatic complaints and anxiety disorders were more prevalent among sexually abused children (Green, Russo, Navratil, & Loeber, 1999), and research consistently documents that sexual abuse may be more related to high-risk sexual behaviors (Buzi et al., 2003; Fergusson, Horwood, & Lynsky, 1997; Robertson, Baird-Thomas, & Stein, 2008). Sexually abused girls in the justice system, in particular, report poorer mental health such as more suicide attempts and more negative feelings about life than their female counterparts that do not report sexual abuse (Goodkind, Ng, & Sarri, 2006). Any type of abuse though, particularly sexual and physical abuse, places youth at risk for both internalizing and externalizing behaviors such as violent and nonviolent delinquency and aggression (Herrera & McClosky, 2003; Gore-Felton, Koopman, McGarvey, Hernandez, & Canterbury, 2001). Moreover, experiencing both forms of abuse

Traumatology 17(2) have been shown to have even worse outcomes and problem behaviors, and this co-occurrence is more common in clinical versus community samples (Chandy, Blum, & Resnick, 1996; Green et al., 1999). However, it is important to note that while experiencing abuse does increase the risk for a variety of adolescent problem behaviors, most sexually and/ or physically abused children do not engage in delinquent behavior as teens. While the majority of studies examining gender differences in trauma exposure and PTSD have found higher rates among juvenile offending girls than among juvenile offending boys, not all studies have supported gender differences in trauma exposure among teenage offenders. For example, Abram et al. (2004) examined the prevalence estimates of exposure to trauma and 12-month rates of PTSD among youth involved in the justice system and found significantly more number of boys had experienced at least one traumatic event than girls had (93% of boys compared to 84% for girls). Interestingly, while girls reported fewer traumatic experiences, they were just as likely as boys to meet PTSD diagnoses. Wasserman, McReynolds, Ko, Katz, and Carpenter (2005) and McCabe et al. (2002) also found no significant gender differences among justice systeminvolved youth in rates of PTSD, though those researchers suggest possible methodological issues such as low statistical power, sample selection limitations, and the reliability of measures and diagnostic criteria may have been responsible for their nonsignificant findings.

Trauma Among Lesbians and Bisexual Girls

As previously stated, there have been no empirical studies focusing on trauma among justice systeminvolved lesbians and bisexual girls, though numerous studies have shown that both sexual and physical victimization is especially prevalent among community samples of lesbians and bisexual girls compared to their heterosexual peers. (Austin et al., 2008; Balsam, Rothblum, & Beauchaine, 2005). For example, Saewyc et al. (2006) in a multisample study found that lesbians and bisexual girls reported the highest rates of sexual abuse and physical abuse by family members. Austin et al. conducted a study of womens past abuse victimization experiences and found lesbians reported higher rates of physical and sexual abuse than heterosexual women. Compared to heterosexual women, bisexual women were more likely to report physical abuse beginning in adolescence. Lesbians were also were more likely to report physical abuse in adolescence compared to heterosexual women. Balsma et al. conducted a study, which compared LBG adults with their adult siblings. LGB siblings reported higher rates of childhood sexual abuse, psychological and physical abuse by parents or caretakers, as well as partner victimization and sexual assault. Saewyc et al. also found high rates of sexual

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Graziano and Wagner abuse reported by gay and bisexual boys, which were close to the rates of bisexual girls and lesbians. In conclusion, a growing body of literature supports that lesbians and bisexual girls experience higher rates of sexual and physical abuse than even heterosexual female counterparts. Lesbians and bisexual girls may also be at increased risk for other potentially harmful behaviors and traumatic experiences. Like bisexual and gay boys, lesbians and bisexual girls may experience high rates of parental rejection and violence. For example, DAugelli (1998) found that it was more common for lesbians to be threatened with physical violence and actually attacked, most often by their mothers, when they disclosed their sexual orientation to parents. Other studies document strained family relationships and parental rejection (Salzburg, 1996; Savin-Williams & Ream, 2003; Williams, Connolly, Pepler, & Craig, 2005), school violence (Bontempo & DAugelli, 2002; Hansen, 2007; Kosciw, Diaz, & Greytak, 2008), substance use (Garofalo, Wolf, Kessel, Palfrey, & Durant, 1998; Marshal et al., 2008; Marshal, Friedman, Stall, & Thompson, 2009), suicide risk (Kitts, 2005; Remafedi, French, Story, Resnick, & Blum, 1998; Russell & Joyner, 2001; Silenzio, Pea, Duberstein, Cerel, & Knox, 2007), and high-risk sexual behaviors (Garofalo et al., 1998; Saewyc et al., 2006; Wright & Perry, 2006).

49 School harassment, which is associated with multiple negative academic outcomes, also plagues LGBTQ youth (Harris Interactive & GLSEN, 2005; Henning-Stout, James, & McIntosh, 2000; Murdock & Bolch, 2005; Rivers, 2000). GLSENs 2007 School Climate Survey results revealed that 86% of LGBTQ youth had been verbally harassed, 44% had been physically harassed, and 61% felt unsafe in school due to their sexual orientation (Kosciw et al., 2008). Such types of trauma are directly associated with poor academic performance and truancy (Kosciw et al., 2008). Judges typically interpret such bad behavior at school as the result of antisocial tendencies, best managed by punishment, rather than of PTSD, best managed by treatment.

Current Practices and Policy Current Trends

Historically, girls have typically entered the justice system because of status offenses. Odem and Schlossman (1991) found that in 1920, 93% of the girls brought into the system were charged with status offenses, of whom 65% were charged with immoral sexual activity. In 1950, there was an increase in the number of Black girls entering the system. By the 1980s girls were entering the justice system for more serious crimes as opposed to primarily status offenses. Schaffner (2006) argued, The data reflect a shift away from a criminalization of girls sexual misconduct toward a focus on girls violent crimes (p. 39). Stahl (2008) reported that in 2004, girls comprised only 44% of the total petitioned status offenses. According to the Juvenile Offenders and Victims: 2006 National Report, since 1994, there has been a general decline in juvenile violence, though the proportion of girls violent crimes has increased, particularly for assault (Snyder & Sickmund, 2006). For example, the Violent Crime Index rose 103% for girls between 1981 and 1997, compared to 27% for boys during the same time frame (Acoca, 1999). The trend has continued where the juvenile arrest rate for simple assault increased 19% for girls as opposed to 4% decrease for boys between the years 1997 and 2006 (Snyder, 2005, 2008). Regarding aggravated assault, there was a 24% decrease for boys compared to a 10% decrease for girls during the same period (Snyder, 2005, 2008). Chesney-Lind and Eliason (2006) argued that recent trends in societal perceptions and media portrayals of the potential for violence among lesbians may have serious negative consequences for sexual-minority and ethnic/racialminority women. Majd, Marksamer, and Reyes (2009) found that many of the juvenile justice professionals they interviewed lamented that LGBTQ youth are viewed as mentally ill and sexual predators. One respondent remarked, The whole case was about sensationalizing lesbians . . . [The prosecution] played it like she was a deranged lunatic lesbian

LGBTQ Youth in the Justice System Unique Considerations Related to Families and Schools
The developmental period of adolescence is marked by a number of additional challenges for LGBTQ youth, which affect their overall well-being. In particular, unique issues related to family and school problems have a significant effect on LGBTQ youth. While family dysfunction and poor academic performance are established risk factors for all youth, particularly girls (Acoca & Dedel, 2000; Henggeler, 1987), an extensive study by Majd et al. (2009) outlines how family rejection and school harassment lead to negative outcomes for LGBTQ youth. In their survey of more than 400 justice and legal professions, 90% identified a lack of parental support as a serious problem for LGBTQ youth. Specifically, family rejection often underlies many of the offenses with which LGBTQ are charged, including ungovernability or incorrigibility, runaway, homelessness, survival crimes (i.e., shoplifting and prostitution), substance use, and domestic disputes (Equity Project, 2007, 2008; Feinstein, Greenblatt, Hass, Kohn, & Rana, 2001; Ray, 2006). Irvine in Majd et al. found LGBTQ youth in detention were twice as likely to have been removed from the home due to someone hurting them and more than twice as likely to be detained for running away from home or placement when compared to their heterosexual peers. The findings speak directly to some of the unique challenges faced by LGBTQ youth.

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50 (p. 52). The second trend may result in more harsh treatment by the justice system for women who are perceived as lesbians. According to the authors, these trends affect all girls and women since they serve as a warning of the consequences of countering dominant gender ideals. In general, gender transgressions in any form challenge traditional views regarding acceptable female behaviors. Lesbian and bisexual delinquent girls often enter justice systems that are ill prepared to address their sexuality in affirming ways that often further traumatizes them due to homophobic environments and practices. The ways in which sexism and heterosexism interact may place lesbians and bisexual girls at high risk for justice system involvement as well as for receiving treatment inappropriate and inadequate for meeting their clinical needs.

Traumatology 17(2) are overcharged with sex offenses, and undergo inappropriate treatment such as sex offender treatment and reparative therapy. For example, several interviewees indicated that it is more common for LGBTQ youth to be prosecuted for consensual sex that is age appropriate. In addition, interviewees recounted cases where youth were ordered to receive counseling to address or change their sexual orientation. The sum effect is that LGBTQ sexual identity is targeted, criminalized, and ultimately punished. To illustrate, a case was cited where a judge ordered a young lesbian to be placed in a private hospital for 2 weeks because of her sexual orientation. Once LGBTQ youth enter the justice system, they are often met with a lack of programs and services. Few placements are willing to accept LGBTQ youth, either because they are not competent to do so or cite safety concerns as a major issue (Majd et al., 2009). In general, competent individual mental health and family counselors are scarce (Majd et al., 2009). LGBTQ youth report a host of problems such as abuse inside institutions from peers and staff and discriminatory policies and practices. LGBTQ youth safety inside juvenile justice programs is a major concern. Unfortunately, there have been high rates of physical, sexual, and emotional abuse of LGBTQ youth reported while in custody (Krisberg, 2009; Majd et al., 2009). Sexual-minority youth are targeted by both peers and staff, and in one study, 80% of survey participants stated that safety was a serious problem for sexual-minority youth, and more than 50% of detention staff reported that they know of situations where LGBTQ youth were mistreated because of their sexual orientation (Majd et al., 2009). More specifically, LGBTQ often experience rejection, harassment, and discrimination at the hands of their peers, as well as their caretakers and professionals charged with their care (Estrada & Marksamer, 2006, p. 419), a fact well recognized by juvenile justice officials: I wonder . . . about how their life is now and how much this traumatized them. . . . It would be hard anyway (to be locked up). But (to be) locked up and verbally abused and told this was a bad sick thing (Curtain, 2002, p. 291). In addition to threats to safety, LGBT youth report services and policies unresponsive to their treatment needs and staff unprepared for treating LGBT youth (Urban Justice Center, 2001). Other discriminatory practices include isolating or segregating youth, utilizing overly harshly discipline and harassment. While many delinquent youth may feel that they are not receiving the treatment and services they need, the justice system and other out-of-home systems routinely subject LGBTQ youth to differential treatment, deny them appropriate services and fail to protect them from violence and harassment (Estrada & Marksamer, 2006, p. 415). Examples of just how bad it can get inside the system include the presence of male security personnel, being strapped to beds, forced medication, seclusion, precautions which force disrobing, forced physical exams, and invasive body searches, all of which are almost certainly

Current Practices
Given the preceding, there is a need to examine both the factors that place lesbians and bisexual girls at risk of justice system involvement as well as their unique experiences once they have entered the justice system. The lack of research on LGBTQ youth in the justice system is remarkable since sexualminority status appears to be a risk factor for juvenile justice system involvement, and LGBTQ youth appear to have particularly negative experiences in the juvenile justice system (Urban Justice Center, 2001). Majd et al. (2009) documented how at every stage of contact and processing competent treatment of and services for LGBTQ youth are lacking. They outline practices that serve as barriers to fair treatment when LGBTQ have contact with police and court officials as well as unjust practices within the system. For example, they found that LGBTQ youth have remained a hidden population, where approximately 20% of the juvenile justice professionals interviewed stated that they had not worked with LGBTQ youth in the past 2 years, though they may in fact be an overrepresented group. A combination of different factors contribute to the invisibility of sexual-minority youth. Juvenile justice professionals may lack awareness regarding sexual orientation and/or youth may choose not to disclose information about their sexual orientation. One interviewee estimated that 75% of the lesbian and bisexual court-ordered girls with whom she works typically do not feel comfortable sharing sexual orientation information initially due to safety concerns. Misconceptions on the part of professionals serving justice systeminvolved youth persist, such as the belief that youth are too young to know whether they are LGBTQ, sexual orientation can be changed through treatment, and/or LGBTQ identity is pathological. These misconceptions regarding sexual orientation among key decision makers, juvenile justice professionals, and services providers in turn influence LGBTQ youth contact with system officials. Majd et al. (2009) documented how LGBTQ youth are targeted and abused by police, lack appropriate sentencing options,

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Graziano and Wagner revictimizing for girls who have suffered from abuse (Ford et al., 2007). Even more common practices that employ physical confrontation, isolation, and restraint may retraumatize girls who suffer from PTSD (Hennessey et al., 2004). In general, the environment is marked by staff insensitivity and loss of privacy, which can increase negative feelings for LGBTQ girls and lead to self-harm (Hennessey et al., 2004). Simply spoken, the conditions faced by LGBTQ juvenile offender girls are uniquely grim and greatly reduce the effectiveness of current treatment and rehabilitation efforts.

51 p. 135). MSP makes several recommendations for how to improve treatment services for LGBTQ youth, including (a) creating an inclusive organization culture, (b) recruiting and supporting competent caregivers and staff, (c) promoting healthy adolescent development, (d) respecting privacy and confidentiality, (e) providing appropriate placements, and (f) providing sensitive support services. Adults working with juvenile offending youth need to understand that while minority sexual orientation does not directly lead to criminality, the negative experiences associated with minority sexual status complicates and exacerbates juvenile offending trajectories. Our final recommendation is more and better training and education regarding trauma among delinquent youth, and how this may vary by sexual orientation, should be provided to juvenile justice professionals. In the past decade, juvenile justice systems have placed more emphasis on trauma and its impact on the juvenile offending population. Ford et al. (2007) reviewed recent advances in trauma-related treatment that include (a) trauma screening and assessment, and (b) treatment and rehabilitation of traumatic stress disorders. They emphasize the need for screening and assessments since behaviors that occur in response to trauma resemble delinquent behaviors. Several instruments have been developed to measure trauma and symptoms resulting from traumatic events. Though interventions that target trauma, some of which were designed and evaluated specifically with women, have been implemented, in general there remains a lack of trauma-informed care for youth involved in the justice system. Covington and Bloom (2003) argued that services need to be trauma-informed in order to be effective for women. They propose that trauma-informed treatment (a) take the trauma into account; (b) avoid triggering trauma reactions and/or traumatizing the individual; (c) adjust the behavior of counselors, other staff, and the organization to support the individuals coping capacity; and (d) allow survivors to manage their trauma symptoms successfully so that they are able to access, retain, and benefit from the services (Harris & Fallot, 2001). These recommendations are particularly relevant for sexual-minority youth since their specific traumatic experiences should be considered and retraumatizing triggers be avoided. The limited literature in this area suggests that the behavior of staff is an issue in serious need of adjustment in order to be supportive to all youth regardless of sexual orientation. Finally, sexual-minority youth should have access to trauma-related treatment in order to be able to manage their symptoms.

Recommendations
Given the preceding, our first recommendation is that much more research should be conducted with juvenile offending LGBTQ youth focusing on their unique experiences and treatment needs, particularly in regard to trauma. Many juvenile justice agencies do not collect information about sexual orientation, which limits our understanding of how many delinquent youth identify as LGBTQ. Needs assessments should at least include general information about intimate relationships and the role they play in the youths life. To this end, the National Council on Crime and Delinquency (NCCD) has developed an assessment for girls, called JAIS (Juvenile Assessment and Intervention System), which captures information about sexual orientation in the context of relationships. Juvenile offending girls are not asked directly about their sexual orientation, but instead whether they have a significant/special partner, which gives them the choice to disclose whether they have same-gender relationships. JAIS inclusion of lesbian and bisexual orientations as possible realities in the lives of offending girls marks the importance of being attentive to sexual identity. Needs assessments should also include general information about trauma experienced prior to and during juvenile justice system involvement, with particular attention to sexual orientation violence. Finally, research is sorely needed that examines girls risk factors for and trajectories of juvenile offending and how these may differ as a function of sexual orientation; such research would help elucidate the unique prevention and intervention needs of LGBTQ youth. Our second recommendation is more and better training and education regarding LGBTQ issues among delinquent youth should be provided to juvenile justice professionals. The Model Standards Projects (MSP) work for GLBTQ youth in the juvenile justice system has been cited as a possible resource (Estrada & Marksamer, 2006; Schaffner, 2006). MSP is a national project aimed at establishing a model and disseminating information regarding professional standards for working with LGBTQ youth. The overarching goal of the MSP is to develop a practice tool to highlight the needs of LGBT youth in out-of-home care and improve services and outcomes (Wilber, Reyes, & Marksamer, 2006,

Conclusion
Lesbians and bisexual girls are overrepresented among, and at elevated risk for becoming, juvenile offenders. Lesbians and bisexual girls are at particularly pronounced risk for experiencing trauma, and trauma appears to increase the risk

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52 for juvenile justice system involvement. The justice system is ill equipped to deal with sexual-minority girls and underequipped for addressing issues related to trauma. Moreover, it appears they often inflict further trauma through policies and procedures completely at odds with the needs of LGBTQ juvenile offender girls. Specialized efforts are needed to ensure the protection, safety, and appropriate treatment of all youth, including sexual-minority girls involved in the justice system. Recommended actions include (a) more research with juvenile offending LGBTQ youth focusing on their unique experiences and treatment needs, particularly in regard to trauma; (b) more and better training and education regarding LGBTQ issues among delinquent youth for juvenile justice professionals; and, (c) more and better training and education regarding trauma among delinquent youth, and how this may vary by sexual orientation, for juvenile justice professionals. Declaration of Conflicting Interests
The author(s) declared no potential conflicts of interests with respect to the authorship and/or publication of this article.

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Funding
The author(s) received no financial support for the research and/or authorship of this article.

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