Domestic Violence And The Evolution of Families by Charles E. Corry, Ph.D.
Domestic Violence And The Evolution of Families by Charles E. Corry, Ph.D.© 2002 Equal Justice Foundation
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When primate females enter estrus they often perform coitus twenty to fifty times a day, usually several copulations in succession. Intercourse occurs with any available male though dominant males take first pick. If necessary, the females flirt, solicit, present, and stimulate the male in order to obtain successive coitions. They may 'consort' with one male for several days until he is exhausted, then take up with another, or be passed from male to male.
Primate females emerge from estrus totally exhausted and often with wounds (domestic violence) from spent males who have been repulsed.
Of course the female has no idea who the father of her young actually is, and the males have no biological interest in caring for offspring of such indeterminate parentage. A matriarchal society is thus the norm.
Human females at some time in the remote past evolved away from estrus. One probable reason for the disappearance of estrus is that human males tended to kill too often if their favorite females were shared around the campfire when they came into heat. That tore-up tomcat from the last catfight is nothing compared to the way men go after one another when a woman is involved. As tools and weapons came into use, brute strength was no longer the sole deciding factor in who possessed available women. Baboons may get away with sharing available females, but even in their troops it causes dissension and quarrels.
Such use of tools as weapons may be essential to the development of intelligence. Otherwise the physically-dominant male possesses as many of available females as he is able to, and all that happens is larger males are evolved. In gorillas, for example, the males are two to three times the size of the females, but only limited intelligence is evident, and the species is near extinction. Conversely, humans greatest technological advances are made under the press of war.
Even now the sexual appetites of an aroused woman far exceeds the capability of any one man to satisfy. That in itself still causes more than a few problems, though better managed than estrus could be. Also, by women becoming continuously available for sex, apparently the human race was better able to evolve, to say nothing of survive.
Factors such as the extended child care required for human children before they can survive on their own, and the need to keep a male nearby both for protection and food during the child rearing years contributed as well. As a result, we tend to pair up in couples, and most prefer to remain that way rather than living as individuals even when children are not a factor.
In the not too distant past, men raided neighboring tribes for females and forcibly took them back to live with them. A male would then spend a month in seclusion with his captured “bride” with the intent of impregnating her. Any objections the woman may have had to this arrangement were dealt with violently by the male. From this practice we derive the word “honeymoon.” Once impregnated, the woman would be bound to the tribe that had captured her through her children. Thus, the biological attachment a woman usually feels for her children was used to the advantage of the society. This simplistic scenario was, and is an underlying basis for civilized, technological societies.
For tribal units of a few hundred to a few thousand individuals such intermingling of women, whether by force or by trade, is a biological necessity to preserve genetic diversity and avoid the effects of inbreeding.
Conversely, there is no biological reason for a male to support a child not known to be his own. As a result, steps were taken in many societies to ensure that a woman mated to a male did not have congress with other men. Of necessity, the penalties against an adulteress in the past have been very harsh, and commonly remain so today in many countries.
The patriarchal society associated with the social convention of a nuclear family apparently provides the impetus and drive necessary for civilization to develop.
Where matriarchal societies have endured, the tribes have not advanced beyond the Stone Age, e.g., the !Kung. And, as Amneus (1990) points out, where people in a technological society have reverted to a matriarchal society, they have also returned to a more primitive state as in the ghettos of our inner cities.
Thus, one of the great accomplishments of any patriarchal society was a way to establish lineage. By such means a man could be reasonably certain that he was the father of a woman's children in the long millennia that preceded methods of reliable birth control and DNA testing to determine paternity. As a result, a father took an interest in his known children and attempted to provide for them and their mother.
All civilization rests on the industry of individual fathers providing for their biological offspring and the mother of those children.
Since children are essential to the long-term survival of a society, it was necessary for males to deal with rebellious women in a manner that is now regarded as barbaric. As a result, patriarchy required that the physical relations of a woman be controlled so that the father of her children is known. The issue of whether the patriarchal society that commonly evolves from these biological and historical facts influences today's family violence is examined in our section on patriarchy. In short, no such evidence exists.
Through the millennia, women have chafed under such control, and we hear that rebellion now in the feminist mantra that “A woman should have control of her own sexuality (or body).” Unfortunately, we have presently legislated against such “domestic abuse” while failing to implement a means of ensuring a woman's children are that of the man she is mated with and adequately provide for a child's upbringing.
With the advent of technology, the number of years required to raise a child to independence has increased and the role of the male in a child's education has also grown. In a more primitive society, by age 12 a child might learn to hunt, fish, farm, gather berries and nuts, and other lessons boys and girls had to absorb in order to survive. In our present, infinitely more complex society, a child's education takes many more years.
It would appear that a child must now remain with it's parents until at least age 18 in order to be able to compete, or survive, in our society. Many families are finding that even 18 years is insufficient and they must support the children into their mid-twenties, as any family with a college-bound child will tell you. A child without a father is greatly disadvantaged in the modern struggle to survive in which a college education is a common requirement. Thus, the biological needs of children for both their parents have increased, while our present laws encourage, and even enforce, the separation of the child's parents. That does not bode well for the survival of our society.
We have become fundamentally dependent for our survival on science and technology. Yet the proud men and women who parent graduates in these fields pay a grossly disproportionate price for rearing such children. If our society is to be stable we must couple the rewards of rearing and educating the technological child with our societal requirements.
Clearly, in the past the warrior was biologically rewarded for his aggression, and that formed a basis for human societies for millennia. If we are to move into a stable technological future, the scientist and engineer must be similarly rewarded. Yet aggression must be maintained, for progress disappears without it. A difficult but essential balance if we are to survive. The present draconian domestic violence laws act contrary to this purpose and breed lawyers when we need scientists.
Degrading and demeaning the role of the male in raising children is contra survival in a scientific world. A society that tears fathers from their children and imprisons them on the whims of a vengeful or neurotic woman aided and abetted by a corrupt judicial system cannot long endure.
In order to reinforce our biological needs, the blessing of religion in the form of marriage has been added to structure a couple's relationship, and help insure the survival and development of their offspring. For the most part, the religious structure of marriage has provided a useful foundation for the needs of our species. Unfortunately, with divorce rates above 50%, in the latter half of the Twentieth Century in America we have come to deal with marital relations primarily through law and in the courts. The protection that institutionalized marriage provided children has thus largely been lost. Almost invariably the children go to the mother in a divorce, and with the extensive use of restraining orders, the children are very likely to lose their father.
Nothing else accounts for as many major social problems as fatherless homes. Recent figures from the Department of Health and Human Services confirm that violent crime, drug and alcohol abuse, teenage pregnancy, emotional and behavioral disorders, teen suicide, poor school performance and truancy, as well as other deviant behavior, all correlate more strongly to fatherless homes than to any other single factor, surpassing both poverty and race. The overwhelming majority of prisoners, juvenile detention inmates, high school dropouts, pregnant teenagers, adolescent murderers, and rapists all come from fatherless homes.
Additionally, economics professor Steven Levitt of the University of Chicago and Stanford law professor John Donohue III suggest that legalized abortion in the early 1970s contributed to a drop in crime in the 1990's. Their theory: that unwanted pregnancies brought to term are more likely to produce unwanted children who grow up to become criminals. Teenagers and poor women, they say, were most likely to have abortions when they first became legally available. Hence, the spate of abortions in the 1970s led to a drop of criminal activity in the 1990's.
Another earthquake has ripped through the fabric of families in the last forty years. To ensure the survival of any species, the reproductive act must be a primary biological drive, and pleasurable as well to insure it functions. But with the advent of “The Pill” and disease control, sex has moved from functional to largely recreational for many humans. It is a rare woman who becomes impregnated today during her honeymoon. There is no penalty of pregnancy attached to acts of casual sex for a woman with cheap, easy, safe, and reliable birth control methods. In 1950, Robert Heinlein pointed out (p. 326) that: “Contraception and control of disease is revising relations between the sexes to an extent that will change our entire social and economic structure.”
In the same time interval, conventions and laws against such casual sex and adultery have been largely repealed or ignored. Women are thus free to act out their fantasies with a minimum immediate price to pay. For the individual woman that has been liberating but there is a larger price that society pays if it is to survive. As Patricia Pearson (p. 139) notes: “The Sexual Revolution generated a many-partnered cycle of loving, being left, and leaving, while we amassed scars to make us flinch and ghosts that come to haunt us.”
Conversely, there is a great genetic disadvantage of birth control devices to a male. Males of any species are biologically programmed to spread their seed as broadly as possible if their genes are to survive. With human males, the genetic requirement that their future be ensured by care of their children has not been relaxed in our present civilization. In fact, a father is probably more critical now to a child's upbringing than before effective female birth control became readily available. However, society now places tremendous barriers in a man's way in the form of laws that often punish him, and drive him away, after a woman bears his child.
In a June 21, 1998, column in the Denver Post, Kathleen Parker points out that:
“Millions of children are growing up without fathers, either through divorce or through that special new feminist trend, single-parent-by-choice. An estimated 9 percent of babies today are born to mothers who deliberately sought single parenthood. By the year 2000, according to recent projections, 40 percent of all American children and 80 percent of all minority children will be born out of wedlock. Currently, 1 million teenagers — 12 percent of all 'women' aged 15 to 19 — become pregnant each year. Of those, 70 percent are unmarried.
Meanwhile, almost 27 percent of all children are currently living in single-parent homes, most headed by a mother. A majority of those are growing up poor, untended during many of the working hours — which one might understand to mean 'undisciplined' and 'untaught' — lonely and longing for their missing parent.
...Then there's this: 70 percent of juveniles in state-operated institutions come from fatherless homes; 63 percent of youth suicides are from fatherless homes; 90 percent of homeless and runaway children are from fatherless homes.”
Year 2000 Census findings show that fewer than 25% of American families fit the traditional model. Divorce rates, combined with out-of-wedlock births, mean that a married man and woman living with their biological offspring is the unlikeliest of family constructs today. Demographers predict that half of all babies born in the 1990's will spend some part of their childhood living in a single-parent home.
Other Year 2000 Census findings are that one-third of babies born in the past decade were born to unmarried women, and only 40% of women with children are living with men who may be the fathers of one or more of their children. A woman with children from multiple fathers has almost become the norm.
Paternity testing using current DNA techniques is showing that approximately 30% of the men women claim fathered their child didn't. Paternity fraud has thus become a national scandal.
And so the story goes from many sources: Children without fathers fare poorly in our society. The answer is clear and simple: Put fathers back in the homes of their children. Inasmuch as there is virtually no chance for fatherless children to become the scientists and engineers our society depends on for survival, the collapse of our society is predictable if current trends continue.
History shows that customs and mores evolve slowly. Less than half a century has not been time enough to develop laws and conventions that deal with such a fundamental upheavals in the human condition as readily available birth control and genetic testing. Whether the damage to our society of laws passed during this transition regarding divorce and domestic abuse can be stopped or reversed is questionable.
Any workable laws to control domestic violence must recognize human biology and sexuality. Peering into people's bedrooms and regulating morality are perfect examples of Big Government at its worst. However, existing laws, and the feminist viewpoint, attack the problem of domestic relations by forcibly separating male and female when they quarrel using the most draconian methods of the State. Perhaps we are making the problems worse instead of better? Particularly when children are involved. That is also the opinion of Karl Zinsmeister in his Fathers: Who needs them? article.
Families, in whatever form they take, are our basic social unit. Change the family and the social structures above it come undone. With the “domestic abuse” laws of the 1990's we have embarked, helter-skelter, on a social engineering experiment of vast dimensions with little thought of likely outcomes.
The racial and biological function of “family” is the protection of children and pregnant women. To accomplish that, family organization must be rewarding to all participants, particularly the father. If families are to be preserved, they must offer its members emotional, spiritual, and physical comforts superior to those to be found in casual copulation and living singly. There is a cynical old adage covering this: “Why keep a cow when milk is so cheap?”
At the beginning of the Third Millennium A. D., the disadvantages and dangers of having a family far out way the advantages for a man in English-speaking countries.
When separated from the biological father, his children are simply an impediment to the desires of a woman's new boyfriends. The little ones are thus very likely to be neglected, rejected and, all too frequently, abused. In fact, it has been suggested that “domestic violence” should be referred to as “shack-up violence,” as Mom and her boyfriend(s) are responsible for the very great majority of it, particularly as associated with her children. At the same time the children are often prevented by law from turning to their father. He is very likely now under a restraining order, and any visitation by him is severely curtailed and supervised, if allowed at all.
In cases where a mother charges her mate with domestic abuse, it is also probable that the she has, or will accuse the father of sexual or child abuse in order to gain advantage in a custody battle. The courts and social services then treat him as a monster who must not be allowed near his children. If the father is granted visitation rights, the woman is quite likely to use that as one more method of harassing the male. Where are the children to turn for succor?
In the circumstances, many fathers who may dearly love their children, find they have little choice but to abandon them as they haven't the money for a protracted legal battle that does no one any good except the lawyers. Cathy Young points out that: “So-called 'runaway dads' are often 'driven-away dads': they vanish because their ex-wives keep them away.” Society then further denigrates such men by referring to them as Deadbeat Dads.
As Prof. Amneus points out:
A judge will try a divorce case in the morning and place the children in the mother's custody. He will try a criminal case in the afternoon and send a man to prison for robbing a liquor store. The chances are three out of four that the criminal he sends to prison grew up in a female headed household just like the one he himself created that morning when he tried the divorce case. He can't see any connection between the two cases. The time lag prevents him: the kids he placed in the mother's custody were toddlers and the criminal he sent to prison was in his teens or twenties. Toddlers don't rob liquor stores.
In a 1999 article in Women's Quarterly, Stephen Baskerville points out about fatherless homes that:
“...nothing else accounts for as many major social problems. Recent figures from the Department of Health and Human Services confirm that violent crime, drug and alcohol abuse, teenage pregnancy, emotional and behavioral disorders, teen suicide, poor school performance and truancy all correlate more strongly to fatherless homes than to any other single factor, surpassing both poverty and race. The overwhelming majority of prisoners, juvenile detention inmates, high school dropouts, pregnant teenagers, adolescent murderers, and rapists all come from fatherless homes.
That is not to say that all children from fatherless homes become criminals but it is quite clear that most criminals do come from fatherless homes. Further, it is very rare for a child from a fatherless home to excel in school. It seems obvious then that society should do everything within its power to keep children connected with their fathers. Instead under current laws and courts, the State drives fathers away.
Our evolution, and present sociology, all suggest that removing the male from child rearing retards the child. Under the patriarchy of the last five millennia, human males have evolved to protect their women and children. Conversely, the current domestic abuse laws thwart the biological requirements of children at every turn. Whether that is by design, or is an unintended consequence, is immaterial. The result is a disaster for any children of the couple. And experience shows that such disasters will be propagated to the children of such children.
If we looked, perhaps there are better ways than the current draconian laws to handle a couple who quarrel? And what couple doesn't at some point? If violence is involved, it is clear that it is mutual combat about 50% of the time. In at least 25% of such cases any violence is exclusively the woman attacking the male. Yet under current laws, e.g., the Violence Against Women Act (VAWA), the blame is placed exclusively on the male. For example, see Satel's essay.
Where the underlying cause of the violence is associated with addiction, chemical or hormonal imbalance, or other health problems in the male or female, or both, lets fix the problem, not the blame .
If a couple simply likes to fight, and the damage is limited to shouting matches, or minor pushing and shoving, might we be better off simply leaving them alone? Typically couples grow out of that stage or separate of their own volition. And what of the estimated 10%-15% of couples who voluntarily enjoy some level of sadomasochism?
Except for the tiny fraction of women and men who engage in dangerous violence, probably less than 1% of domestic violence cases, other means of dealing with domestic relations are more appropriate than arrest and detention. Instead, current law forbids mediation or counselling, makes arrest mandatory, does not allow the charges to be dropped when reality strikes the next morning, and produces a high-probability that the family is destroyed. Virtually always it the man who is arrested regardless of the actions or wishes of the female involved. Aside from the civil rights issues, is it desirable to rent the fabric of our society by destroying families?
The law, lawyers, and the courts are designed to and function for the purpose of assigning blame. If Susan kills John, then the law and the courts will work to assign the blame and the degree associated with his demise. Did she act in self-defense, or was the killing premeditated, are questions that can best be answered in a court of law. Conversely, if John and Susan are engaged in a shouting match that may lead to some pushing and shoving, is such marital discord a problem that can be solved in a criminal court? We think not! If the shoving leads to blows, should this be considered assault and battery? If so, then this is probably proper action for the police and the courts. But why should battery be treated differently between a couple who have been sexually intimate and a man and a woman who may not even know each other? Why should the gender of the participants even enter into the question of blame before the court if men and women are to have equal rights?
Of necessity, court actions are adversarial. If we are to attempt to solve the problem of domestic abuse and violence, rather than just assigning blame, an adversarial approach would seem to be the worst possible method to resolve the conflicts between two emotionally-upset people who are already fighting.
First, and foremost, it seems self evident that most of the cases of domestic violence leading to arrest today should not be in the courts at all. Few problems can be solved by simply assigning the blame, particularly if gender is the primary factor for the blame, and an adversarial approach is the only option.
When you attempt to force people to do something, one of the most common reactions is rebellion. Throughout history that rebellion has led to violence. Why is it now presumed that forcing a male to become a street person by charging him with domestic abuse will not lead to violence? If , and that is a mighty big IF, a couple needs outside help, agencies of the State should be the last, not the first to be called upon. However, if called upon the State should act to preserve domestic harmony, as it is clearly charged to do, rather than promote domestic strife as it does today.
At present the law forbids mediation in cases of domestic violence. Wouldn't it make more sense to try mediation first? Questions of medical problems with the participants would also seem to be important to resolving the problems. Does one, or both the parties have a drug addiction that affects their behavior? These are problems that mediation or counselling can readily address and perhaps answer. Certainly such an approach would minimize the impact on the children, rather than maximizing the trauma for the little people as the present laws do. Conversely, such an approach would violate feminist dogma that it always, and solely the male responsible for the problems a couple is having.
If investigation reveals the couple should be apart, arbitration provides a civilized means of providing for a peaceful and equitable separation of two emotionally-charged people. Clearly the police and courts cannot perform mediation, and arbitrate very poorly. Further, it is a virtual certainty that arresting the male will heighten the level of combat rather than control it.
As of 1999, the only quantifiable effect claimed for VAWA is that it has cut the number of men killed by their female intimate partners more than in half. But even that claim is specious, as we show from Department of Justice statistics in our women who kill section. Such homicides have been steadily declining since at least 1976 and VAWA wasn't passed until 1994.
Perhaps if we gave men the same powers of arrest and prosecution that women have been given we could cut the number of women killed by their male partners in half as well? Just automatically arrest both parties when 911 is dialed and put the children in a foster home? If civil rights are no barrier to the mandatory arrest of a man, why should women be treated differently? Studies clearly show that the woman is solely responsible for the violence in 25% to 30% of such cases and it is mutual combat 50% of the time. On that basis the woman should be taken into custody at least 75% of the time the police are called if arrests for “domestic violence” are to be mandatory.
The present laws do not provide a basis for stopping or preventing domestic violence. They do, however, provide the basis for establishing a police state. That, inevitably, will lead to even greater violence.
As a social tool, it appears the present domestic abuse laws are the worst imaginable approach.
A pervasive theme in the present feminist movement, and the resultant laws, is that a male and female who quarrel should be separated regardless of their personal wishes or the needs of their children. The woman who opened the first shelter for battered women, Erin Pizzey, regards this as the planned destruction of the family. The We the People Web site echoes and expands on that theme.
In the feminist creed, males are looked on as the root of all evil. Thus, when a man and woman fight, it is the male who is to be arrested and forced from his home and family with no possibility of communicating with them except under court supervision, or through their respective attorneys. Mediation or arbitration, that could well settle their problems at a modest cost, and perhaps preserve the family, is expressly forbidden.
The real issue for the long-term preservation of our society isn't a quarrel between a man and a woman, but what effect the events have on their children. The present laws, evolved with feminist guidance largely under the strange logic of the Clinton and Gore administration serve attorneys well as they grow rich under such conditions. But it serves the children poorly as their fathers can only rarely afford the legal fees incurred in addition to maintaining a second residence after being thrown into the street. Thus, fathers are often forced to abandon their children and society then denigrates them further with references to Deadbeat Dads.
The celebrated author, Robert Heinlein, observed that the only valid laws are those that protect children and pregnant women. Clearly, the current family and domestic abuse laws do not. In fact, the present domestic violence laws would seem calculated to provoke more violence. While that is useful for generating more cash and grants for the gender feminists, we do not think it is the proper and decent approach.
We must move away from simply placing the blame for domestic violence on men, who are at most only half of the equation. Instead, the focus should be on solving the problem.
A human male has a large genetic stake in ensuring the survival of his children and studies show a child is safest with their biological father. Conversely, a man has very little biological interest in helping another man's child. Logic thus dictates keeping the child with its natural father whenever possible. It is also essential that the father of the child be unambiguously identified for this bond to hold.
In the past, and lacking better means, societies evolved the institution of marriage in an attempt to ensure that the paternity of a woman's child was known. However, if paternity can be established more certainly by other means, then the legal basis for marriage is outmoded. But the welfare of children is more important than ever.
The technology for routinely determining paternity became available in the 1990's and should be used as a tool for bonding families rather than simply a weapon in paternity suits. The religious beliefs of a couple in marriage should be used to help ensure the welfare of the children where it can be done without interference by the State in an individual's beliefs.
To ensure the future of our children, we suggest that there is a fundamental need to move toward an individual, irrevocable contract between a man and a woman who want to have children. The societal terms of the contract might be that:
• A child should not be conceived and carried to term unless the biological father is identified and voluntarily agrees to a contract with the mother for raising the child. There are a variety of methods besides abortion to ensure this. Birth control would certainly be a preferable and acceptable option to most.
• The child is certifiably the biological offspring of the father. Today DNA testing provides an economic means to unquestionably determine a child's paternity and that should be done at birth.
• That a woman who, nonetheless, brings a child to term without a contract with the biological father would be ineligible for any support from the father or the State. Further, she would be financially and legally responsible for any crimes the child might commit throughout the child's life. Alternatively, the child could be placed for adoption with the father, if known, having first right to adopt his child.
• As parties to the contract, both parents agree to provide for, mutually raise, and educate the child to the best of their abilities until the child reaches a minimum age of 18.
• That they will carry out the terms of the contract regardless of their emotional or physical relationship while their youngest child is under 18-years old. Such an agreement would not be revocable by either party, or the courts, except in cases of death or total disability of one or both of the parents.
• Beyond the first eighteen years of the child's life the contract could be renewed at four year intervals for as long as the parents felt it to be desirable.
• The State should encourage cohabitation by a child's biological parents while the child is developing. Preferably the couple would bind themselves together by marriage under the terms of their religion. Such measures as education and tax incentives, low interest housing loans, child care facilities, etc. might help couples stay together during their children's formative years. Conversely, such benefits must not be available to parents who live apart or to a single parent of either sex unless the other parent is dead or disabled.
• Conflicts between a child's parents that they cannot resolve themselves should be decided, insofar as possible, by mediation and counseling. Arbitration would be a next step. The police and courts should not be involved in individual relationships except in extreme circumstances and then only after arbitration fails unless the use of deadly violence is evident beyond a reasonable doubt.
• As with any contract, readily enforceable penalties should be available to punish a parent who fails in their obligations to their child. Tax penalties, say the loss of a deduction, come to mind as an impersonal first-step punishment. More extreme measures should be limited to those few cases where mediation or arbitration has failed.
• If the parents separate while their children are under 18 years of age, they would hold joint custody of the children unless one of the parents breaks the terms of their contract. Full custody would then automatically go to the parent who upheld the contract terms.
• Unless their religious vows or contract explicitly allowed polygamy or polyandry, a man who sired a child with another woman, or a woman who bore another man's child, would surrender all custody rights to the children of the previous relationship. However, the financial obligation to support those children would remain intact.
• In the unfortunate event that the parents do not live together, insofar as practicable monetary support should be paid directly in support of the child. The terms of such support would be part of the original parental contract. There would be no legal obligation for the non-custodial parent to support the custodial parent in any manner.
Similar contracts might protect the property rights of the individuals when they cohabitate, with or without children. The interest of the State in the relationships between a man and a woman should be primarily concerned with protecting children and pregnant women.
Other than enforcing the terms of such contracts, and providing for an equitable dissolution normally after the end of their contract term, or in cases of death or disaster, the State should not concern itself with individual relationships.
For those whose religious beliefs govern their relationship, the State should not become involved in those terms except to the minimum extent necessary to protect the children under whatever covenants society evolves. Thus, if a couple marry under religious terms that forbid divorce, e.g., Catholicism, then it should not be within the power of the State to grant the couple a divorce. The couple could, of course, ignore their religious beliefs and settle their secular contract if they wished to dissolve their relationship and no minor children are involved. Other than the terms of their contract, and the protection of children they bear, their beliefs must be of no concern to the State.
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