Criminalization Of Sex Work Research Articles

“Shut Up and Take My Money!”: Revenue Chokepoints, Platform Governance, and Sex Workers’ Financial Exclusion

Sex work regulation is often debated from the perspective of state control: legalization vs decriminalization, ‘end demand’ vs criminalization. Ultimately, these debates center the State as the most significant arbiter in sex workers’ ability to conduct business. This paper contends that while state legislation has a significant effect on the material lives of sex workers, the terms of service of the US-based, privatized financial industry has a more immediate and widespread affect. Most sex workers make use of online payment applications as well as social media, even though both are highly discriminatory toward sex workers, regardless of the legal status of one’s employment as a sex worker, or even the laws in which the worker conducts their business. Rather than being treated as a luxury or privilege, access to both the worldwide web and the global network of banking are essential rights that enable full participation in contemporary society. Through an analysis of platform governance and revenue chokepoints, this paper argues that payment intermediaries function as an extra-legal regulation of sex work that has a more profound effect on sex workers’ material reality than State legislation, as these intermediaries control how they are able to secure business and be paid for it without having to answer to a voting demographic. Most of the world’s major social media and payment processing applications are based in the United States, which enables it to export the repercussions of the stigmatization and criminalization of sex work even within the boundaries of countries with differing legislation.

Understanding the Law’s Relationship with Sex Work: Introduction to ‘Sex Work and The Law: Does the Law Matter?’

This special issue of The International Journal of Gender, Sexuality and Law, edited by Laura Graham, Victoria Holt and Mary Laing, brings together a range of voices and knowledges on the issue of Sex Work and the Law: Does the Law Matter? Mirroring global and national sex worker campaigns, official consultations, policy and wider debates over the last two decades, there has been much academic interest in the legal responses to sex work (Scoular and O’Neill, 2007; Graham, 2017; Munro and Della Giusta, 2008). Much of this work has evaluated the varied current legal responses to sex work, how they impact sex workers’ lives, and how the law might be reformed. There is also significant academic and governmental interest in comparative research looking at legal responses across jurisdictions (Armstrong and Abel, 2020; Levy, 2014). This special issue takes a broad, critical approach to the relationship between sex work and the law, inspired by Jane Scoular’s (2010) question: does the law matter in sex work? In doing so, this special issue offers an interdisciplinary exploration of the complex relationship between law and sex work. This issue addresses global trends towards criminalisation of sex work, often predicated upon stopping trafficking, and considers the impact of these trends on sex workers, their rights, their working practices, and their marginalisation. It further examines the law’s response to new and emerging issues, such as COVID-19 and digital sex work, reflecting particularly on the varied impacts of over- and under- regulating sex work spaces. This special issue finally reflects on sex workers’ resistance – to current laws, to the expansion of laws, and to their lack of inclusion in debates around law. Throughout this issue, the voices of sex workers are integrated and prioritised, reflecting a commitment to inclusion of expert knowledges around the world.

HIV and mental health services for female sex workers

The disproportionate burden of HIV infection among female sex workers is well established, with systematic reviews and meta-analyses documenting a global HIV prevalence of 10·4% among cisgender female sex workers1 and 27·3% among transgender female sex workers.2 UNAIDS estimates that female sex workers have 30 times greater odds of acquiring HIV than do women overall.3 Sociostructural factors, such as criminalisation of sex work, gender inequality, poverty, and intersecting forms of stigma and violence, drive both the increased HIV risk and poor HIV care and treatment outcomes in female sex workers.

The Consequences of Conflating Trans-ness and Vulnerability

The Consequences of Conflating Trans-ness and Vulnerability

Peer Counsellor Training for Sex Workers: A Pilot Program in Lekwungen Territory (Victoria, BC)

Sex workers face significant stigma when accessing mental health services, due to the history of criminalization of sex work and the resulting negative biases in the healthcare sector. Peers Victoria Resources Society is a sex worker advocacy organization who partnered with the researchers to develop and implement a pilot program on peer-counsellor skills development for sex workers incorporating trauma informed practice. The course sought to build on leadership, capacity and strengthen solidarity while acknowledging societal stigma, in hopes that this pilot could result in supplementary care to mainstream mental health services for this underserved community. Interviews were conducted with eight participants prior to and following the 10-week course. Participants reported increased competency in basic counselling skills such as reflective listening, and all noted the applicability of these skills in their personal and working lives. Suggestions were made to scaffold future course content to manage both academic and emotional learning.

Seeing pre-screened, regular clients associated with lower odds of workplace sexual violence and condom refusal amidst sex work criminalization: findings of a community-based cohort of sex workers in Metro Vancouver, Canada (2010-2019)

BackgroundResearch that accurately represents how characteristics of sex work clients relate to sex workers’ labour conditions is crucial for informing evidence-based legislation which upholds sex workers’ human rights. As little quantitative research has examined how seeing regulars (repeat clients) impacts sex workers’ occupational safety, particularly under ‘end-demand’ criminalization in Canada, our study aimed to explore how seeing mostly regulars shapes workplace sexual violence and client condom refusal.MethodsWe drew on longitudinal data from a community-based open cohort of 900+ sex workers in Vancouver, recruited via time-location sampling during day and late-night outreach to indoor, outdoor, and online solicitation spaces. We used logistic regression analyses and multivariable GEE confounder models to 1) describe correlates of seeing mostly pre-screened, regular clients, 2) identify associations between seeing mostly regulars and odds of experiencing occupational outcomes of workplace sexual violence and client condom refusal, and 3) examine the interaction between seeing mostly regulars and work environment on workplace sexual violence and client condom refusal.ResultsParticipants’ median age was 35, and 55.6% had completed high school. Over the 9-year study (n=925), 20.9% (193) experienced 282 events of workplace sexual violence and 40.2% (372) faced 702 events of client condom refusal. In multivariable GEE confounder models, seeing mostly regulars was associated with reduced odds of sexual violence (AOR 0.73, 95%CI 0.53-1.02, p=0.067) and client condom refusal (AOR 0.70, 95%CI 0.57-0.86). In multivariable GEE confounder models examining the additive interaction between seeing mostly regulars and work environment, participants who saw mostly regulars and primarily worked in outdoor or informal indoor venues faced significantly lower odds of experiencing workplace sexual violence (AOR 0.69, 95%CI 0.49-0.95) and client condom refusal (AOR 0.64, 95%CI 0.52 -0.80) relative to those who worked in the same venues and did not see mostly regulars.ConclusionOur findings highlight protective effects of seeing pre-screened regulars within a criminalized setting. Removal of ‘end-demand’ client criminalization is needed to enable sex workers to effectively screen clients, support HIV/STI prevention, and advance sex workers’ human rights.

Criminalization and rhetorical nondiscrimination: Sex work and sexual diversity politics in Rwanda

Sex that is considered nonnormative or undesirable is often subject to state sanction. In Rwanda in 2009 there was an effort to criminalize sex work and same-sex sex, but ultimately only the criminalization of sex work occurred. What explains these different outcomes? Although both groups are at higher risk for HIV transmission because of social stigma, these concerns were not sufficient. The political salience of the human rights argument that nondiscrimination is an essential government commitment in postgenocide Rwanda was used to reject criminalizing same-sex sex. However, neither politicians nor most civil society activists thought this human rights argument was applicable to sex work. Although criminalizing lgbt people was considered socially divisive, criminalizing sex work was considered necessary. Understanding these different outcomes reveals the limitations of human rights arguments on the regulation of sex in East Africa.

“What will we do if we get infected?”: An interview-based study of the COVID-19 pandemic and its effects on the health and safety of sex workers in the United States

Emerging evidence suggests that sex workers face unique and profound risks arising from the COVID-19 pandemic. To illuminate the pandemic's effects on sex worker health and safety and identify intervention opportunities, from May–August 2020 in-depth interviews were conducted with a purposive sample of 15 sex workers, four service providers and two individuals who were both. Sampled sex workers included eight people of color, eight cisgender women, five cisgender men, three non-binary people, and one transgender woman. Using Conservation of Resources Theory to define impacts on sex worker resources and resulting health and safety implications, a deductive thematic analysis was conducted. Seven resources were threatened due to the pandemic: work opportunity, sex work venues, social support, health services, money, food, and housing. The loss of these resources was exacerbated by stigma – notably sex work criminalization – and significantly undermined health and safety by increasing food and housing instability, increasing risks of violence, and diminishing safer sex negotiation. Six resources were activated in response: social support, digital skills, health knowledge, non-sex work employment, money, and resilience. While social support had numerous benefits, investing digital skills and non-sex work employment were generally of limited impact. The pandemic's negative health and safety effects were most profound at the intersections of race, gender, class, and migration status. These findings suggest sex workers need urgent and ongoing support, with investments in social support and sex work decriminalization likely to have the greatest effects on health and safety relative to and beyond the COVID-19 pandemic.

Decriminalizing Domestic Violence and Fighting Prostitution Abolition: Lessons Learned From Canada’s Anti-Carceral Feminist Struggles

This article offers a cautionary tale for efforts to decriminalize domestic violence through a retrospective analysis of Canadian feminist legal activism to decriminalize sex work. Both domestic violence and sex work are contested terrains of activism, litigation, and scholarship and have come up against the disparate views of criminalization as necessary to protect women from violence, versus criminalization as compounding women’s potential risks for violence. Through the example of Canadian feminist jurisprudence in R v Bedford, wherein the Supreme Court of Canada recognized the endangerment of women as resulting from the criminalization of sex work, I explore the liminal space following this decision, and how regressive legislation was introduced to re-entrench carceralism in the breach of a seeming feminist victory. My focus is on how carceral feminism continues to occupy the liminal space as a force of colonial violence, further endangering Indigenous women. I draw linkages between several violent murders of street-involved Indigenous women and the severing of allyship among feminists, sex workers, and Indigenous women over the potential decriminalization of sex work. Finally, I suggest that opposition to the decriminalization of sex work is successfully argued by an emerging force of carceral feminism: neo-abolitionist feminists who have appropriated a politics of abolition and, yet, may have deepened carceralism in the lives of Indigenous women.

Why Decriminalise Prostitution? Because Law and Justice Aren’t Always the Same

Leigh Goodmark’s work on domestic violence argues for alternatives to criminal justice to ‘solve’ issues of gendered violence. The criminalisation of sex work and prostitution is rarely discussed in this context—a rather odd omission given the increasing trend towards ‘criminalising demand’ and counter-calls for decriminalisation in this domain. In this article, we bring the two debates into conversation, using Goodmark’s work to bring analytical clarity to the prostitution debate and connect sex work to wider social justice debates in feminist anti-violence circles. We aim to move the conversation beyond retribution and the view that law is justice to outline a vision of justice for sex workers grounded in the principles of rights, recognition and representation. By contextualising the decriminalisation of prostitution within the framework of a wider anti-carceral justice movement, we seek to build alliances for social justice that transcend the current divide.

Quashing demand or changing clients? Evidence of criminalization of sex work in the United Kingdom

AbstractThe use of regulation of sex work is undergoing sweeping changes across Europe and client criminalization is becoming very widespread, with conflicting claims about the intended and actual consequences of this policy. We discuss changes in demand for paid sex accompanying the criminalization of prostitution in the United Kingdom, which moved from a relatively permissive regime under the Wolfenden Report of 1960, to a much harder line of aiming to crack down on prostitution with the Prostitution (Public Places) Scotland Act 2007 and the Policing and Crime Act of 2009 in England and Wales. We make use of two waves of the British National Survey of Sexual Attitudes and Lifestyles (NATSAL2, conducted in 2000–2001 and NATSAL3, conducted in 2010–2012) to document the changes in both the amount of demand for paid sex and in the type of clients that have taken place across the two waves, and their possible implications for policies that frame prostitution as a form of crime.

The experiences of sex workers accessing HIV care services in Bulawayo, Zimbabwe.

Although sub-Saharan African countries have rolled out massive HIV treatment and care programmes, there is little evidence of these having embraced key population groups particularly female sex workers. Due to the criminalisation of sex work in countries like Zimbabwe, research on HIV and its impact on this group is sparse. The absence of an enabling environment has hindered access to HIV care and treatment services for female sex workers. To gain an in-depth understanding of the experiences of female sex workers accessing HIV care and treatment services to enhance programming and planning for this key population group. This study was qualitative and phenomenological. Data saturation determined the sample size of 20 participants. Data was collected using in-depth interviews that were audio recorded, transcribed, and subjected to thematic content analysis. Our findings demonstrate varying dynamics between the private and public sector HIV care services for sex workers, with facilitators and barriers to access to care. Health workers need sensitization and training in the provision of differentiated care. For effective linkage to and retention in care an enabling environment is critical.

The Plight of Female Cameroonian Migrant Sex Workers in N\u2019Djamena, Chad: A Case of Intersectionality

In most countries, sex-work is criminalized and frowned upon. This leads to human rights abuses, especially for migrant female sex workers. The burden is heavier on migrant female sex-workers whose gender and foreign citizenship intersect to produce a plethora of adverse health, social, and legal outcomes. This phenomenological study explores the intersectionality of individual factors leading to human rights abuses among migrant Cameroonian female sex workers in N’Djamena, Chad. Ten female sex workers and two key-informants were interviewed, and being a small sample, they gave detailed information about their experiences. The data was later analyzed using thematic analysis. Participants narrated experiences of social exclusion, exposure to diverse abuses, and health risks due to gender, immigrant status, and illegality of sex work. The experiences of female migrant sex workers, within contexts of sex work criminalization, are exacerbated by the intersectionality of these factors. Women endure several vulnerabilities in many African countries, more so when they have to survive on sex work as foreigners in a country where the act is illegal.

The Double-Edged Sword of Health and Safety: COVID-19 and the Policing and Exclusion of Migrant Asian Massage Workers in North America

Migrant Asian massage workers in North America first experienced the impacts of COVID-19 in the final weeks of January 2020, when business dropped drastically due to widespread xenophobic fears that the virus was concentrated in Chinese diasporic communities. The sustained economic devastation, which began at least 8 weeks prior to the first social distancing and shelter in place orders issued in the U.S. and Canada, has been further complicated by a history of aggressive policing of migrant massage workers in the wake of the war against human trafficking. Migrant Asian massage businesses are increasingly policed as locales of potential illicit sex work and human trafficking, as police and anti-trafficking initiatives target migrant Asian massage workers despite the fact that most do not provide sexual services. The scapegoating of migrant Asian massage workers and criminalization of sex work have led to devastating systemic and interpersonal violence, including numerous deportations, arrests, and deaths, most notably the recent murder of eight people at three Atlanta-based spas. The policing of sex workers has historically been mobilized along fears of sexually transmitted disease and infection, and more recently, within the past two decades, around a moral panic against sex trafficking. New racial anxieties around the coronavirus as an Asian disease have been mobilized by the state to further cement the justification of policing Asian migrant workers along the axes of health, migration, and sexual labor. These justifications also solidify discriminatory social welfare regimes that exclude Asian migrant massage workers from accessing services on the basis of the informality and illegality of their work mixed with their precarious citizenship status. This paper draws from ethnographic participant observation and survey data collected by two sex worker organizations that work primarily with massage workers in Toronto and New York City to examine the double-edged sword of policing during the pandemic in the name of anti-trafficking coupled with exclusionary policies regarding emergency relief and social welfare, and its effects on migrant Asian massage workers in North America. Although not all migrant Asian massage workers, including those surveyed in this paper, provide sexual services, they are conflated, targeted, and treated as such by the state and therefore face similar barriers of criminalization, discrimination, and exclusion. This paper recognizes that most migrant Asian massage workers do not identify as sex workers and does not intend to label them as such or reproduce the scapegoating rhetoric used by law enforcement. Rather, it seeks to analyze how exclusionary attitudes and policies towards sex workers are transferred onto migrant Asian massage workers as well whether or not they provide sexual services.

Police Enforcement of Sex Work Criminalization Laws in an "End Demand" City: The Persistence of Quality-of-Life Policing and Seller Arrests.

The purported goals of commercial sex work criminalization policies in the United States have shifted over the past two decades as local jurisdictions have adopted End Demand reforms. These reforms aim to refocus arrest from individuals who sell sexual services to buyers and facilitators, representing a departure from the quality-of-life, nuisance-focused approach of the late twentieth century. This article presents a case study examining enforcement of commercial sex laws in Chicago, a city that has been heralded as a leader in End Demand reforms. Our case study utilized annualized arrest statistics from 1998 to 2017 and individual arrest reports (n = 575) from 2015 to 2017. Commercial sex arrests by the Chicago Police Department have declined substantially over the past two decades, falling 98.4% from its peak. However, our analysis suggests that sellers of sexual services continue to face the heaviest burden of arrest (80.5%) and officers generally continue to approach commercial sex as a quality-of-life issue. We argue that this divergence between the goals and implementation of End Demand are the result of three institutional factors: street-level bureaucracy, logics of spatial governmentality, and participatory security. Our results suggest that the ideals of End Demand may be incompatible with the institutional realties of urban policing.

Keep the South Dirty and Our Needles Clean

Keep the South Dirty and Our Needles Clean Laura McTighe (bio), Catherine Haywood (bio), Deon Haywood (bio), Danita Muse (bio), and Iris Gottlieb Click for larger view View full resolution [End Page 120] hirty years ago, Women With A Vision (wwav) was just an idea, thought up by a collective of Black women on a front porch in New Orleans, Louisiana. The year was 1989, and the so-called War on Drugs had already been raging for nearly two decades. Black women were increasingly being demonized as "welfare queens" in order to justify the total gutting of the social safety net, just as sensationalized stories about "crack babies" were used to criminalize Black mothers and users in a rapidly ballooning prison industrial complex. The impacts of these policies were lethal. Rates of hiv infection were peaking and the numbers of new hiv infections among Black people exceeded those of white people; those differences still hold today. By the early 1990s, hiv was the second leading cause of death for Black cisgender women between the ages of twenty-five and forty-four. wwav's founders shared an intimate knowledge of how the twin epidemics of hiv and mass criminalization were decimating their communities. They also saw how funding and supportive services were systematically being denied to their people. And so, from their health and human service positions citywide, the wwav foremothers did what Black women always do: they set their hands to building what their community needed.1 This essay is grounded in thirteen years of organizing and research partnership with wwav. Together, we tell the stories of wwav's more than three decades of Black feminist struggle at the intersections of harm reduction and abolition in New Orleans. The methods that our founders used to keep forgotten and dying Black people struggling with addiction alive in the early 1990s were the same as those used to fight back against post–Hurricane Katrina sex work criminalization. These methods continue to guide wwav today in our work around decriminalizaiton. As our foremother Danita Muse puts it, "For wwav, practicing harm reduction in the South has demanded first and foremost the tenacity to believe in what we believed in. It's also helped us to hone our ability to change with the times and continue to be open to new ways of doing things, which we are always developing in partnership with the drug user and sex worker communities with whom we stand." This essay is built, as wwav's work has always been, in relationships and by doing the work.2 You Have to Build a Relationship As the story goes, Danita Muse and Catherine Haywood locked eyes across a crowded health department conference room at the height of the aids epidemic. At the time, Catherine, or "Lady," as she is more often called, was working for the Children's Pediatric aids Program on a project to increase access to hiv testing among people who inject drugs. Danita was [End Page 121] working for the Office of Substance Abuse (now the Office of Behavioral Health) and running support groups for people struggling with addiction. Both women had seen firsthand that the white-led hiv response efforts were only targeting gay bars in their outreach efforts; none were reaching out to poor Black people in New Orleans's ten housing projects, which had the highest documented incidence of hiv transmission in the city. When the Office of Public Health called a meeting after the city received an influx of funds to address a surging syphilis epidemic, both women were in attendance. This time, however, the outreach maps were following the epidemiology. When the city's zip codes were called out, Catherine and Danita claimed the ones to their uptown neighborhoods, including the St. Thomas, Magnolia, Melpomene, and Calliope Projects. That was when their relationship started. They drove the city—Danita in her truck, Lady in her car—to make deliveries. The health department simply wanted them to drop off boxes of condoms at bars, grocery stores, beauty shops, and laundromats. It took a few weeks before Danita and Catherine figured out that the people who ran these businesses were selling their free condoms...

Using Anticarceral Feminism to Illustrate the Impact of Criminalization on the Lives of Individuals in the Sex Trades

This research study is informed by anticarceral feminism to understand and highlight the experiences of violence and oppression that individuals in the sex trade experience as a result of police stings, raids, and incarceration. We present findings from 23 in-depth, qualitative interviews with men, women, and trans individuals who were arrested in the Los Angeles sex trade. More specifically, we explore experiences of violence that occurred interpersonally, systemically, and institutionally. Such experiences examine police violence, arrest and incarceration, coercion, and client violence. The findings from this research shed light on the impact the criminalization of sex work has had on research participants in terms of their physical health and mental health, economic security and opportunities for growth and education, and their sense of freedom and autonomy. We also attend to the role that intersecting identities might have played during their encounters with the police. This study explored these aspects while being mindful that the policies and procedures followed by the police are born out of a carceral state. We conclude with antioppressive and antiviolent implications for social work practice, policy, research, and education as we imagine the next decade of social work in relation to sex trade.

Co-occurring Threats to Agency Among Female Sex Workers in Baltimore, Maryland.

Driven largely by the unequal distribution of power, female sex workers (FSW) globally bear a disproportionately high burden of HIV, sexually transmitted infections, and interpersonal violence. Prior literature has identified a number of multi-level factors that may serve to constrain FSWs’ agency, or their ability to define and take action to realize goals. Among these are work-based violence and substance use, which are potentiated by the criminalization of sex work and structural vulnerability. Quantitative research related to U.S.-based FSWs’ own sense of agency, as well as the barriers that may impede it, is sparse. We sought to identify patterns of various threats to agency and explore to what extent they were associated with perceived agency among a cohort of 381 FSW in Baltimore, Maryland, United States, using latent class analysis. Latent class indictors were past-six-month experience of client-perpetrated sexual violence, client-perpetrated physical violence, homelessness, food insecurity, arrest, daily crack-cocaine use, and daily heroin use. Perceived agency was measured using the short form of the Pearlin Mastery Scale. We identified three typologies of threatened agency among women in our sample: a “threatened by structural factors, drug use, and violence” class, a “threatened by structural factors and drug use” class, and a “less threatened” class. Mean perceived agency score was significantly lower for the class characterized by client-perpetrated violence than for either of the other classes. This suggests violence, in the context of deeper, structural power imbalances embedded in hunger, homelessness, and drug use, may dramatically reduce one’s sense of agency and operate as a critical barrier to empowerment. Our study adds important insights to the broader FSW community empowerment literature and supports the need for interventions to bolster both individual and collective agency among U.S.-based FSW, including interventions to prevent sex work-related violence.

Monica Jones

Abstract The following is an interview with activist Monica Jones conducted by Che Gossett and Eva Hayward. In this interview, Jones talks about her activism against the criminalization of sex work, recounting how the program Project ROSE, which was a revealing collaboration between the university and the police, functioned through carceral logics to detain and then according to a carceral economy of innocence, criminally prosecute or “reeducate” sex workers or those profiled as sex workers. Jones shows how the university is part of the carceral continuum and is a site of Black trans and sex worker and prison abolitionist struggle, which has intensified in the current organizing against police on campuses and entanglement of university and the prison-industrial complex and the policing functions of administration and university governance. Jones also shows how this is an HIV/AIDS activist issue given that the criminalization of sex work is bound up with from gentrification, displacement, and how that is exacerbated with COVID-19.

The impact of end-demand legislation on sex workers' access to health and sex worker-led services: A community-based prospective cohort study in Canada.

Following a global wave of end-demand criminalization of sex work, the Protection of Communities and Exploited Persons Act (PCEPA) was implemented in Canada, which has implications for the health and safety of sex workers. This study aimed to evaluate the impact of the PCEPA on sex workers' access to health, violence, and sex worker-led services. Longitudinal data were drawn from a community-based cohort of ~900 cis and trans women sex workers in Vancouver, Canada. Multivariable logistic regression examined the independent effect of the post-PCEPA period (2015-2017) versus the pre-PCEPA period (2010-2013) on time-updated measures of sex workers' access to health, violence supports, and sex worker/community-led services. The PCEPA was independently correlated with reduced odds of having access to health services when needed (AOR 0.59; 95%CI: 0.45-0.78) and community-led services (AOR 0.77; 95%CI: 0.62-0.95). Among sex workers who experienced physical violence/sexual violence or trauma, there was no significant difference in access to counseling supports post-PCEPA (AOR 1.24; 95%CI: 0.93-1.64). Sex workers experienced significantly reduced access to critical health and sex worker/community-led services following implementation of the new laws. Findings suggest end-demand laws may exacerbate and reproduce harms of previous criminalized approaches to sex work in Canada. This study is one of the first globally to evaluate the impact of end-demand approaches to sex work. There is a critical evidence-based need to move away from criminalization of sex work worldwide to ensure full labor and human rights for sex workers. Findings warn against adopting end-demand approaches in other cities or jurisdictions.