11 Wake Forest L. Rev. Online 111

Gregory S. Parks*


Hazing has been a persistent issue for centuries.[1]  Little empirical research, or research drawing on empirical data, has been conducted on what would meaningfully curtail it.  Researchers have agreed, however, that among the necessary hazing prevention factors are: (1) organizational leadership;[2] (2) more certainty (and less focus on severity) in sanctions;[3] and (3) better organizational engagement with alumni.[4]  Recently, Aldo Cimino proposed another more radical, solution—embrace and reform hazing, not abolish it.[5]  While defining hazing has long been a challenging task,[6] workable definitions abound.[7]  Yet still, building upon Cimino’s work, this Article proposes that pledging—a ritual-based, aboveground, well-supervised, demanding, protracted, yet nonabusive process—is critical to hazing prevention.  In short, especially among adolescents, while deviant behavior is normal, motivational and learning mechanisms can extinguish it.[8]  When people perceive that something they value may be lost by continuing their deviant behavior, these “commitment costs” are one of the motivators for deviant behavior desistance.[9]  By contrast, and more specifically, when members have a process that they value and respect—a process by which prospective members are integrated into their organization—they are more likely to abide by that process.

In Part I, this Article explores the role that both ritual and rites of passage play in societies, and how they serve as a foundation for why people haze.  In Part II, this Article explores the relationship between hazing and the psychological needs of victims.  In Part III, this Article explores the relationship between hazing and the organizational commitment.  In Part IV, this Article explores the relationship between hazing and group cohesion.  In Part V, this Article explores how hazing is seen as instrumental education.  In Part VI, this Article explores the relationship between adversity and personal growth. Finally, in Part VII, this Article explores the nature of supervision needed to reduce hazing.  In sum, this Article argues that, more or less, these factors—ritual and rites of passage, victims’ psychological needs, desire for organizational commitment and group cohesion, and personal growth, all within the context of robust supervision—are valued by hazing perpetrators and victims.  Further, organizations that can embrace the fact that hazing perpetrators’ and victims’ beliefs are substantiated by empirical support can chart a path toward offering meaningful pledge processes.  Even more, a ritual-based, rites-of-passage pledge process is a critical component of hazing prevention.  Ultimately, organizations that adapt, rather than abolish, the pledge process to accommodate the factors valued by hazing perpetrators and victims will thus create a process that members will more likely abide by, thereby reducing instances of hazing overall.

I. Ritual and Rites of Passage

Pledging underscores the importance of ritual, rites of passage, and tradition.  As a general matter, a ritual’s function and purpose, in any society, is to help those who experience it cope with reality by replicating and confronting the social norms that are part of the social order.[10]  Rituals are also how people invoke, understand, and legitimize relationships mediated by authority, power, and value.[11]  When it comes to “the ritual” that fraternity and sorority members must endure, it is an experience that organization members see as aligning their values with the organization’s values.[12] For example, sorority members see ritual as a bonding experience that assists them in becoming not just friends but sisters and as a reminder of their organization’s purpose.[13]  This perception is closely related to the perception of ritual as a tradition that keeps the sorority and its purpose in existence through its history.[14]

Rites of passage are social and arbitrary activities that are understood as natural, necessary, and they are also normal activities that feel “nonarbitrary and grounded in reality.”[15]  They are a mechanism for normalizing a particular power structure by setting the framework of reality that becomes the unquestioned basis of acceptable behavior.[16]  Fraternity and sorority members view hazing as a rite of passage and part of organizational tradition.[17]  For example, in Black Greek-letter organizations (“BGLOs”) members often view hazing as a necessary rite of passage to membership.[18]  Among BGLO members, hazing is valued as part of living the legacy of the organization, and members cite tradition as a reason for knowingly indulging in hazing activities.[19]   Research has underscored this finding in Black Greek-letter fraternities (“BGLFs”).[20]  Similarly, victims often view hazing as a necessary rite of passage or tradition.[21]  Individuals rationalize hazing as valuable because they believe it is merely part of campus or organizational tradition.[22]

Among BGLO members, tradition is a major justification in the continuation of hazing.[23]  Members state that hazing is part of living the legacy[24] and believe that it will help victims value traditions.[25]  BGLO members view hazing as part of their organization’s ritualistic ceremonies[26] and a rite of passage, causing new members to better appreciate the organization, develop closer ties with one another, and value traditions more.[27]  Supporters of the “rite of passage” argument contend that it “mimics African traditions” whereby African initiations require initiates to endure several stages of trial.[28]  However, many members also state that hazing rituals do not have any particular meaning and are merely beneficial because of their traditional value to the organization.[29]  In Black Greek-Letter sororities (“BGLSs”), members admit to maintaining the use of hazing in order to create a strong appreciation in new members for the organization and the influence of tradition.[30]

II. Psychological Needs

Victims endure hazing to fulfill their psychological needs.[31]  Some victims feel that hazing provided motivation for achievement, citing a feeling of accomplishment after completing hazing, while others report increasing focus, developing character and discipline, and feeling mentally stronger overall.[32]  Victims are also motivated by their need to belong.[33]  New members accept hazing because of a need to feel like part of the team.[34]  Research has shown that young women, compared to young men, have higher levels of needing to belong,[35] which may explain why, in one survey, most of the positive feelings that sorority women associated with hazing were that it results in “fitting in” and “a sense of belonging.”[36]  In BGLOs, some members decide to endure hazing out of fear of rejection.[37]  

A new member’s need to belong leads him to form a “new” self as a member of the group, socially isolating himself from other campus groups in the process.[38]  Group members consider this “rebirth” of identity via hazing necessary to place greater emphasis on the advancement of the group, rather than solely on one’s self.[39]  Both fraternity and sorority members have expressed that they grew or gained something by participating in the activities and now have a “shared story.”[40] Hazing is intended to strip the new recruits of their individual identities and integrate them into the institutional identity.[41]  

Victims are also driven by their need for esteem and respect.[42]  Hazing victims in BGLFs sometimes report feeling more self-confident after enduring the hazing process.[43]  Many also seem to fear losing respect from their peers, including earning the derogatory label of “paper” if they are not able to withstand the process.[44]  Hazing ensures that newcomers demonstrate proper respect and the ability to be integrated into the group.[45]  For victims, hazing garners a sense of respect from other members.[46]  In BGLFs, members felt hazing ultimately benefited them by proving their respect and love for the fraternity.[47]  Those who admit to being hazed report enduring hazing processes in order to gain respect from chapter members.[48]

The implementation of the no-pledge policy in BGLOs has made some members feel that they were “left out” due to the fact they could not complete the traditional pledging process.[49]  The level of respect that a brother receives from his chapter members remains inextricably linked to the type of initiation process he experienced.[50]  “Paper brothers”—those who do not experience hazing—receive much less respect than brothers who endure abusive hazing processes.[51]  Accordingly, a majority of members rank the stigma of receiving the derogatory label of “paper” as among the top two reasons contributing to the prevalence of hazing in their chapters.[52]  Despite this policy, some members were willing to participate in an underground pledging process in order to gain respect from their fellow members.[53]  Of those who admit to being hazed, many aspirants report enduring hazing processes in order to gain respect from chapter members.[54]

III.  Organizational Commitment

Hazing is seen as fostering respect and organizational commitment among victims.[55]  As noted by researchers Gentry McCreary and Joshua Schutts, hazing motivating factors include the desire to extract loyalty, respect, and solidarity from new members.[56]  This may be observed in a number of ways.[57]

In BGLFs, current members believe that new members are more likely to work harder for their organizations following hazing[58] and better appreciate the organization and value traditions more.[59]  And there is some support for these assumptions mainly in the research on severity of initiation and organizational liking.[60]  In their classic studies in the 1950s, psychologists Elliott Aronson and Judson Mills found that individuals who are more severely initiated in an effort to join an organization are, on average, increasingly likely to have stronger positive feelings toward that organization.[61]  They offered cognitive dissonance as a theory to explain what drives the severe initiation/liking relationship.[62]  First, cognitive dissonance theory holds that inconsistency among cognitions may cause an uncomfortable psychological tension.[63]  In an effort to reduce that tension, the person alters one or more cognitions to make them agree with one another.[64]  Aronson and Mills explained cognitive dissonance in the context of severe initiations as follows:


      No matter how attractive a group is to a person it is rarely completely positive, i.e., usually there are some aspects of the group that the individual does not like.  If he has undergone an unpleasant initiation to gain admission to the group, his cognition that he has gone through an unpleasant experience for the sake of membership is dissonant with his cognition that there are things about the group that he does not like.[65]


Dissonance can be reduced either by overvaluing the attractiveness of the group or denying the severity of the initiation.[66]

Hazing also tests new members, ensuring their loyalty and commitment to the organization before benefits are granted to them.[67]  In BGLOs, hazing is seen as promoting the intrinsic values of the organization by creating a mechanism to get rid of individuals who are only interested in the organization for “superficial” purposes.[68]  In essence, it ensures that newcomers demonstrate proper respect and the ability to be integrated into the group.[69]  One of the main reasons why BGLO members haze is because they perceive it as a method that creates a strong sense of organizational loyalty.[70]  In BGLSs,  many members  question the hazing processes they went through, yet they admit to maintaining the use of hazing in order to create a strong appreciation in new members for the organization and the influence of tradition.[71]  Some members feel efforts to end hazing may be harmful to organizations even if the members disapprove of hazing.[72]  This belief has been expressed by BGLO members more broadly who believe that hazing makes members more likely to work harder for their organizations.[73]

These beliefs have empirical support.[74]  If a member shows organizational commitment by completing the initiation process and the subsequent hazing, it reinforces the group hierarchy by allowing senior members to exert authority over the new members.[75]  Anthropologist Aldo Cimino offers an evolutionary psychological basis to understand this phenomenon.[76]  Our more primitive ancestors resolved potential threats to group cooperation by forming unions with others and enforcing fairness.[77]  Cimino’s Automatic Accrual Theory suggests that organization members believe new members pose a “problem” for their organization.[78]  Hazing solves this problem of “free riding” by forcing new members to display their commitment to the group before they receive the benefits of group membership.[79]  Members use hazing to make sure that new members are willing to fully participate and contribute to their joint organization.[80]  Without going through this process, members cannot allow prospective members to enjoy the full benefits or status of their organization.[81]  Stated differently: hazing is the response from current members to prevent newcomers from “exploiting” potential benefits of membership.[82]

Not surprisingly, hazing is a way for an organization to build prestige by making it difficult for new members to join.[83]  Research on fraternity hazing in predominantly White fraternities has found that a relationship between self-perceived prestige and toughness of pledge program suggests that fraternity members have a tendency to make it tough for others to share the privilege of membership status.[84]  Contemporarily, within the U.S. Naval Academy, hazing frequently occurs in the freshmen year to the “plebe[s]” as a weeding-out process to retain committed future officers.[85]

IV. Group Cohesion

Hazing may provide the kind of crucible, more so than processes that are less intense and shorter in duration, that aids in group cohesion.[86]  The emotions and feelings that are created through hazing are meant to become the link that holds the group together and establishes membership.[87]  Group cohesion refers to the connections and relationships people form with individuals and a group as a whole.[88]  Psychologist Leif Braaten proposes five elements necessary to make a group cohesive: “1) attraction and bonding; 2) support and caring; 3) listening and empathy; 4) self-disclosure and feedback; and 5) process performance and goal attainment.”[89]  Pregroup conditions that also have an impact on group cohesion are diversity of the group and the level of effectiveness of the orientation, training, and contracting.[90]  Braaten also suggests that leaders focus on building a sense of community within the group, being able to solve conflicts, and limiting the amount of avoidance and defensiveness in group sessions in order to facilitate group cohesion.[91]

Self-disclosure, the process where an individual communicates information about themselves on purpose,[92] is correlated with interpersonal liking and trust.[93]  People tend to disclose more information to people who they like and trust.[94]  In fact, the more positively people felt about self-disclosure, the more likely they were to like a stranger.[95]  People on the receiving end of self-disclosure were also more likely to like the person and view it as a sign of trust and liking.[96]  The more someone is disclosed to, the more likely they are to disclose information to someone else.[97]  Also, when someone perceives that they are liked by the receiver, they are more likely to like them back.[98]  The higher the intimacy level of the disclosure, the more extreme the effects.[99]  There is also evidence that people may like people more because they have disclosed information to them, rather than the reverse.[100]

Confidentiality and trust are also important in creating a cohesive group.[101]  Trust can be a crucial hurdle to clear in an organization that is comprised of longstanding and new members.[102]  The basic processes that build trust among group members are: (1) evaluation, in which members assess the benefits of putting their trust into the other members, (2) commitment, where a member puts their trust in another and works hard to keep them as a member and to satisfy their needs, and (3) role transition, which occurs as activities or ceremonies where the individual will change their expectations and relationship with the other members.[103]  Factors that affect trust are how long an individual has been with the organization, their previous reputation, their qualifications, and their commitment.[104]

Group cohesion is not something that happens spontaneously.[105]  Proximity and opportunity impact how people establish friendships.[106]  Time spent together in formal settings negatively predicts closeness while time spent together in informal settings positively predicts closeness.[107]  Casual friendships may form around 30 hours, friendships around 50 hours, good friendships around 140 hours, and best friendships after 300 hours.[108]  

Organization members believe that hazing cultivates bonds between hazing victims, between hazing victims and their perpetrators, and between hazing victims and a broader organizational lineage.[109]  Generally, fraternity and sorority members continue to perpetuate hazing because they view it as a means to foster and develop group-member cohesion and create stronger bonds.[110]  More specifically, fraternity members relate their hazing experience to the cultivation of brotherhood.[111]  They often link a previous hazing activity with the intention of forming a “socially worthy” brotherhood; therefore, convincing themselves that this activity is necessary.[112]  When talking about their hazing experiences, men use words such as “team building” and creating “shared experiences.”[113]

Sorority women link their experiences to the organization’s values, such as friendship and teambuilding.[114]  They believe that their hazing activities align with the organization’s values because the activities create bonds between the group and promote friendship and teambuilding.[115]  The idea that these hazing activities create lasting bonds and friendships between the sorority members ensures that the activities continue.[116]  To make these activities seem acceptable, women similarly use “socially worthy” concepts.[117]  These “socially worthy” ideas include ideas of friendship and teambuilding, which seem to justify activities where they were demeaned or mistreated.[118]

When looking at BGLOs, hazing is linked to activities presumably designed to foster fictive-kinship ties (e.g., brotherhood), which convinces members that what they are doing is necessary.[119]  For example, in a qualitative study, one BGLO member explained that “those memories help you build a bond with those that you are going through it with.”[120]  Interestingly, this notion of bonding is voiced by many BGLO members, especially among line-brothers and line-sisters.[121]  This finding—that hazing is perceived to create a bond within the pledge line—has been underscored in other studies.[122]  BGLF members often cite bonding, willingness, and acceptance  as some of the many justifications for hazing.[123]  For BGLS members, a main justification for a positive view of hazing is the concept of “purpose” or the goal of unifying the pledge class.[124]

Hazing is also perceived as promoting bonds between the pledges and the current members.[125]  Members justify hazing by reflecting upon their completion of the hazing process and citing that they developed greater feelings of closeness with the chapter members due to enduring a shared experience.[126]  As such, both the role of organizational tradition—even at the sub-unit level—and the role of rites of passage significantly impact the perpetuation of hazing.[127]  Members continue hazing out of respect for tradition.[128]  Individuals view hazing as valuable, common within groups, and believe that it is merely part of campus or organizational tradition.[129]  Others view it as a cycle—that those who endured the experience must now inflict the same experience upon newcomers.[130]  In BGLOs, hazing is valued as part of living the legacy of the organization, and members cite tradition as a reason for knowingly indulging in hazing activities.[131]  Research has underscored this finding in BGLFs.[132]  In addition, BGLO members often view hazing as a necessary rite of passage to membership.[133]

Their beliefs are not unfounded. Hazing supports and maintains groups by “stimulating cognitive, behavioral, and affective forms of social dependency in group members.”[134]  Among victims, the external threat and self-sacrifice within groups that come along with hazing may aid group cohesion.[135]  Their experience of shared hardship serves as a cohesive force between them.[136]  And the heightened emotional arousal, precipitated by hazing, may result in victims mistakenly assuming what causes them to feel such emotions—e.g., confusing fear with deep interpersonal connection.[137]  Even between perpetrators and victims, hazing may stimulate deep emotional connection.[138]

V. Instrumental Learning

Among those who subject others to hazing, two typologies emerge: a hazer is either the “teacher” or the “fool.”[139]  The “teacher” is someone who sees himself as a provider of knowledge about the organization and who feels the need to use whatever methods necessary to assess the knowledge of newcomers.[140]  As such, hazing is viewed as a method of instrumental education.[141]  Arguably, hazing instructs the new members on the appropriate knowledge, skills, and attitudes of the group,[142] such as the organization’s history, creeds, and names of the other members.[143]

The perpetuation of hazing within BGLOs can be partially attributed to the fact that many members perceive their hazing experiences to result in numerous benefits, including educating new members.[144]  While the majority of BGLO members generally agree that there is no place for hazing in an organization,[145] BGLF members often justify hazing to promote intrinsic values.[146]  For example, members report that hazing encourages them to learn material about their fraternities through the imposition of negative reinforcement.[147]  Some organization members view hazing as a means to foster and develop mental and physical resilience—not only developing toughness but also creating better members.[148]  BLGO members often attribute the hazing experience with producing better people.[149]  BGLS members in particular rationalize their behaviors, believing that membership in their organization has shaped their “Black womanist identities.”[150]

VI. Adversity and Personal Growth

German philosopher Nietzsche once noted that “what doesn’t kill you makes you stronger”—suggesting that adversity can foster growth.[151]  Social scientists have found support for said proposition.[152]  Within the realm of post-traumatic growth (“PTG”) research, psychologists Richard Tedeschi and Lawrence Calhoun define PTG as “positive psychological change experienced as a result of the struggle with highly challenging life circumstances.”[153]  In response to such traumatic experiences, an individual is able to develop appreciation and wisdom in the long term.[154]  Some researchers studying the connection between PTG and psychological wellbeing suggest that positive growth in the forms of autonomy, environmental mastery, positive relations with others, purpose in life, and self-acceptance is facilitated by experiencing hardships.[155]  These researchers argue that although “it is highly possible that trauma may leave an individual sadder,”[156] those individuals also may, in the long run, have an enhanced appreciation of what is important will ultimately drive future growth.[157]

Many factors, especially personality traits, will affect how an individual grows from trauma.[158]  Those with the dominant traits of hope and gratitude correlate with higher levels of mental health.[159]  Similarly, PTG “is more likely to occur among those who are low in depression, and high in self-esteem and satisfaction with life.”[160]  That being said, when confronted with loss and trauma, those strengths will ultimately help an individual flourish.[161]  PTG can be explained by the fact that adversity can challenge people’s points of views, which can motivate them to cultivate their strengths and even discover new ones.[162]

VII.  Supervision

Almost a century ago, United States Supreme Court Justice Louis Brandeis noted, “[p]ublicity is justly commended as a remedy for social and industrial diseases.  Sunlight is said to be the best of disinfectants; electric light the most efficient policeman.”[163]  Indeed, violent crimes more frequently occur at night than in the day,[164] and even electric light serves to reduce crime.[165]  By its very nature, hazing is typically conducted in private, away from any adult supervision.[166]  Researchers have found that “[a]round forty-six percent of off-campus hazing takes place in private in comparison to the eleven percent that occurs off campus in public.”[167]  Locations devoid of watchful adults, such as locker rooms, weight rooms, hotel rooms, and school buses, are prime areas for hazing to occur.[168]  Indeed, “all the evidence points to lack of supervision as a breeding ground for hazing.”[169]  Education about hazing and antihazing policies are not enough; professional football players still hazed new players after receiving warnings not to haze, one of which was given mere hours before the hazing incident.[170]

In the 1980s, Greek-life organizations grew larger than the national offices’ abilities to supervise them.[171]  For fraternities and sororities, hazing became more violent after it was pushed “underground.”[172]  One explanation for hazing turning more dangerous is “the fact that when youth are left to guide one another without supervision they tend to push some acts to the extreme because they have no understanding of reality.”[173]  Given these findings, increased supervision has been recommended to prevent hazing.[174]  Indeed, Greek-letter organization chapter supervision, via advising, is a key component to casting light on the issue of hazing and a meaningful part of prevention.[175]

There are several factors that may explain why supervision is important to prevent hazing.  Teenagers and young adults need role models, and if competent adults are willing to engage with them, “then [they] might actually have real role models to follow instead of the deviant masculinity that is the inevitable result of continued hazing.”[176]  Additionally, some posit that college students who “grew up with an unprecedented amount of supervision and guidance,” need more structure, and “many are not prepared for an abrupt transition into a hands-off environment, which may increase the already dangerous level of risk these students face.”[177]  Moreover, teenagers and young adults may simply lack good judgment, and supervision curbs and mitigates their more reckless impulses.  Even courts have recognized teenage boys


      particularly in groups where the herd instinct and competitive spirit tend naturally to relax vigilance, are not accustomed to exercise the same amount of care for their own safety as persons of more mature years . . . . Thus rough-housing or hazing . . . is behavior which is not so extraordinary as to break the chain of causation between the school’s failure to supervise and the injury to the student.[178]


In the 1970s, criminologists Lawrence Cohen and Marcus Felson put forth the criminological Routine Activities Theory, which postulates that structural changes in everyday “routine activities” influence criminal opportunity and affect crime rates for direct-contact predatory violations.[179]  Direct-contact predatory violations are illegal conduct during which “someone definitely and intentionally takes or damages the person or property of another.”[180]  For a direct-contact predatory violation to occur, three elements must be present: (1) a motivated offender, (2) a suitable target, and (3) the absence of a capable guardian who could guard against a violation.[181]  The absence of one of these elements prevents, or reduces, the likelihood that the direct-contact predatory violation will occur.[182]  A motivated offender must have both “criminal inclinations and the ability to carry out those inclinations.”[183]  A suitable target may be a person.[184]  Additionally, a target’s suitability can increase for reasons such as accessibility, visibility, or ability to transport the object.[185]  However, the presence or creation of a capable guardian may eliminate criminal opportunity.[186]  Capable guardians may include persons with no official crime control authority who nonetheless are personally willing to intervene or to summon those with the authority to intervene.[187]

Sociologists and criminologists studying college student behavior have used the Routine Activities Theory to posit that certain types of deviance occur so frequently on college campuses because of the convergence of three factors discovered by Cohen and Felson.[188]  These findings have been translated into hazing-prevention methods.[189]  Moreover, research in a range of contexts shows that bullying is more likely to take place when capable guardians are not present to monitor such behavior.[190]  The converse is also true: “Perhaps the greatest deterrent to bullying behavior is the presence of adults who are watching and are willing to intervene.”[191]  However, supervision is more than just watching, “it is a concerted effort to create a healthy community . . . .”[192]


For generations, institutions, organizations, and individuals have struggled to make sense of hazing and find solutions to address it.  One solution has been under their noses all along—the process by which new members are brought into an organization.  Ritual and rites of passage are natural experiences to human development and growth, especially in adolescents.  They connect individuals to organizational values and transition individuals from the status of aspiring to that of being.  People have a range of psychological needs that overcoming adversity satisfy.  People tend to more deeply commit themselves to organizations they had to work to join.  Going through adversity together or being put through it by others serves to deepen bonds among members of the same cohort and even with their tormentors.  And difficult experiences offer the type of context needed to learn practical information and skills for organizational membership.  However, combining all of these elements together to bring new members into organizations, especially those on college campuses, requires adult supervision.  For these reasons, an above-ground, ritual-based, rites-of-passage pledge process that is well-supervised, demanding, protracted, yet non-abusive is critical to addressing hazing.  The ceiling placed on such a process is the law and morality.  Institutional and organizational insurers and host institutions must have a say on the front end.  And it must be recognized that this is but one of several crucial pieces needed to address hazing.


      *.   Associate Dean of Strategic Initiatives and Professor of Law, Wake Forest University School of Law.

      [1].   Gregory S. Parks et al., White Boys Drink, Black Girls Yell: A Racialized and Gendered Analysis of Violent Hazing and the Law, 18 J. Gender Race & Just. 93, 94–95, 97 (2015).

      [2].   See generally Gregory S. Parks & E. Bahati Mutisya, Hazing, Black Sororities, and Organizational Dynamics, 43 Law & Psych. Rev. 25 (2019) (discussing why organizational leadership matters in preventing hazing).

      [3].   Gregory S. Parks, The Failure of Zero-Tolerance Policies in Addressing Hazing, Penn St. L. Rev. Penn Statim (forthcoming 2022) (advocating that the deterrence theory assumes formal sanctions to help ratify deviant behavior).

      [4].   Gregory S. Parks et al., Old Heads: Hazing and the Role of Fraternity and Sorority Alumni, 46 Law & Psych. Rev. (forthcoming 2022).

      [5].   See Aldo Cimino, Embrace & Reform: Ending Hazing’s Prohibition Era 7 (2020), http://www.aldocimino.com/cimino_2020.pdf.

      [6].   See Aldo Cimino, Defining Hazing: Why Popular Definitions are Misleading and Counterproductive, 32 J. Higher Educ. Mgmt. 135, 135 (2017).

      [7].   Gregory S. Parks & Sarah J. Spangenburg, Hazing in “White” Sororities: Explanations at the Organizational-Level, 30 Hastings Women’s L.J. 55, 76 (2019).

      [8].   Terrie E. Moffitt, Adolescence-Limited and Life-Course-Persistent Antisocial Behavior: A Developmental Taxonomy, 100 Psych. Rev. 674, 690 (1993).

      [9].   See id. at 690, 695 (explaining that changing contingencies can include marriage, employment, or military service).

     [10].   Roger D. Abrahams, Foreword to the Aldine Paperback Edition of Victor Turner, The Ritual Process: Structure and Anti-Structure, at ix (Aldine Paperback ed., 2017).

     [11].   Catherine Bell, Ritual: Perspectives and Dimensions, at xi (1997).

     [12].   See, e.g., Mari Ann Callais, Sorority Rituals: Rites of Passage and Their Impact on Contemporary Sorority Women 91 (2002) (Ph.D. dissertation, Louisiana State University) (on file with author).

     [13].   Id. at 95–96.

     [14].   Id. at 98.

     [15].   Bell, supra note 11, at 135.

     [16].   Catherine Bell, Ritual Theory, Ritual Practice 77–78 (1992).

     [17].   Shawn D. Peoples, Tragedy or Traditions: The Prevalence of Hazing in African American Fraternities and Sororities 41 (2011) (Ph.D. dissertation, Saint Louis University) (on file with author).

     [18].   Id. at 64.

     [19].   See Robert Lay, College Students’ Motivations for Participating in Hazing Rituals of Black Greek Letter Organizations 81–82 (2019) (Ph.D. dissertation, Temple University) (on file with author); Dwayne Joseph Scott, Factors that Contribute to Hazing Practices by Collegiate Black Greek Letter Fraternities During Membership Intake Activities 33–34 (2006) (Ed.D. dissertation, Arkansas State University) (on file with author).

     [20].   See generally Scott, supra note 19 (presenting findings of a study examining the factors that lead to hazing in BGLFs).

     [21].   Peoples, supra note 17, at 22, 64.

     [22].   Kyle D. Massey & Jennifer Massey, It Happens, Just Not to Me: Hazing on a Canadian University Campus, 18 J. Coll. & Character 46, 50, 55 (2017); Scott Alden Mathers & Jackie Chavez, When Hazing is Not Hazing: Media Portrayal of Hazing: Developing a Typology. Introducing the TAIR Model, 7 Soc. Scis. 158, 158 (2018); Kellie D. Alexander, Hazed Perceptions: A Qualitative Analysis of College Students’ Definitions and Perceptions of Hazing in Student Organizations 70 (2018) (M.A. thesis, Colorado State University) (on file with author); David R. Montague et al., Hazing Typologies: Those Who Criminally Haze and Those Who Receive Criminal Hazing, 3 J. Victims & Offenders 258, 269 (2008).

     [23].   Scott, supra note 19, at 34, 49–50.

     [24].   Lay, supra note 19, at 82.

     [25].   Scott, supra note 19, at 65.

     [26].   Peoples, supra note 17, at 22–24.

     [27].   Scott, supra note 19, at 65.

     [28].   Id. at 16.

     [29].   Id. at 38.

     [30].   Eugena Lee-Olukoya, Sisterhood: Hazing and Other Membership Experiences of Women Belonging to Historically African American Sororities 114 (2010) (Ph.D. dissertation, Illinois State University) (on file with author).

     [31].   See Scott, supra note 19, at 39.

     [32].   Id.

     [33].   Id. at 16, 39–40, 55.

     [34].   See Emily Feuer, Understanding Hazing Perceptions of Students and Administrators Using a Four Frame Model 18 (2019) (Ph.D. dissertation, University of Albany, State University of New York) (on file with author).

     [35].   See Leibovich N. et al., The Need to Belong (NB) in Adolescence: Adaptation of a Scale for its Assessment 1, 5 (2018), https://juniperpublishers.com/pbsij/pdf/PBSIJ.MS.ID.555747.pdf.

     [36].   Heather W. Holmes, The Role of Hazing in the Sorority Pledge Process 53–55 (Mar. 22, 1999) (Ph.D. dissertation, State University of New York at Buffalo) (on file with author).

     [37].   Scott, supra note 19, at 68.

     [38].   Feuer, supra note 34, at 19 (referencing perceived “skills” members gain by undergoing hazing).

     [39].   Id. at 18–19 (explaining the sociological perspective that, “[t]hrough the organization’s new member process, new members have manipulated identities that place more emphasis on the group over the individual to help them create a new identity as a fraternity/sorority member and feel a sense of belongings with their peers.”).

     [40].   Jenny Nirh, Explanations of College Students for Engaging in Hazing Activities 114 (2014) (Ph.D. dissertation, University of Arizona).

     [41].   See, e.g., Carlos Linhares de Albuquerque & Eduardo Paes-Machado, The Hazing Machine: The Shaping of Brazilian Military Police Recruits, 14 Policing & Soc’y 175, 175–76 (2004) (analyzing a study of hazing in Brazil’s military policy academy).

     [42].   Scott, supra note 19, at 39.

     [43].   Id.

     [44].   Lay, supra note 19, at 60.

     [45].   Montague et al., supra note 22, at 269.

     [46].   See Scott, supra note 19, at 39.

     [47].   Id. at 39, 65.

     [48].   Id. at 39.

     [49].   John A. Williams, Perceptions of the No-Pledge Policy for New Member Intake by Undergraduate Members of Predominantly Black Fraternities and Sororities 93–94 (1992) (Ph.D. dissertation, Kansas State University) (on file with author).

     [50].   Peoples, supra note 17, at 89.

     [51].   Id.

     [52].   Id.

     [53].   Williams, supra note 49, at 94.

     [54].   Peoples, supra note 17, at 89.

     [55].   Id. at 34–35.

       [56].    Gentry R. McCreary & Joshua W. Schutts, Why Hazing? Measuring the Motivational Mechanisms of Newcomer Induction in College Fraternities, 19 J. Cognition & Culture 343, 345–47 (2019).

     [57].   See infra text accompanying notes 67–73.

     [58].   Peoples, supra note 17, at 67, 69.

     [59].   Scott, supra note 19, at 65.

     [60].   Elliott Aronson & Judson Mills, The Effect of Severity of Initiation on Liking for a Group, 59 J. Abnormal & Soc. Psych. 177, 177 (1959).

     [61].   Id.; see also Harold B. Gerard & Grover C. Mathewson, The Effects of Severity of Initiation on Liking for a Group: A Replication, 2 J. Experimental Soc. Psychol. 278, 278 (1966); John Schopler & Nicholas Bateson, A Dependence Interpretation of the Effects of a Severe Initiation, 30 J. Personality 633, 633 (1962).

     [62].   Aronson & Mills, supra note 60, at 177.

     [63].   Leon Festinger, A Theory of Cognitive Dissonance 2 (1957).

     [64].   See id. at 2–3 (discussing and explaining theory of cognitive dissonance).

     [65].   Aronson & Mills, supra note 60, at 177.

     [66].   Id.

     [67].   See Ricky L. Jones, Black Haze: Violence, Sacrifice, and Manhood in Black Greek-Letter Fraternities 54 (2004).

     [68].   Scott, supra note 19, at 35.

     [69].   Montague et al., supra note 22, at 269.

     [70].   Peoples, supra note 17, at 67, 69.

     [71].   Lee-Olukoya, supra note 30, at 114.

     [72].   Montague et al., supra note 22, at 268.

     [73].   Peoples, supra note 17, at 67, 69.

     [74].   See generally Aldo Cimino, The Evolution of Hazing: Motivational Mechanisms and the Abuse of Newcomers, 11 J. Cognition & Culture 241, 244 (2011).

     [75].   Id.

     [76].   Id. at 246.

     [77].   See generally Kathryn Coe & Craig T. Palmer, The Words of Our Ancestors: Kinship, Tradition, and Moral Codes, 16 World Cultures eJournal 1 (2008) (discussing how our ancestors used moral kinship systems to combat threats to the group and created cooperative relationships by encouraging individuals to honor ongoing duties to one another).

     [78].   Aldo Cimino, Predictors of Hazing Motivation in a Representative Sample of the United States, 34 Evolution & Hum. Behav. 446, 447 (2013).

     [79].   Id. at 447–48; Kirsten M. Keller et al., Hazing in the U.S. Armed Forces: Recommendations for Hazing Prevention Policy and Practice 29–32 (2015).

     [80].   Cimino, supra note 78, at 447.

     [81].   Id.

     [82].   Feuer, supra note 34, at 18; see also id. at 19 (referencing perceived “skills” members gain by undergoing hazing).

[83].   D. Thomas Ramey, Group Climate, Campus Image and Attitudes of Fraternity Men Regarding Pledge Hazing 68 (1981) (Ed.D. dissertation, Indiana University).

     [84].   Id. at 88−89.

     [85].   Jana L. Pershing, Men and Women’s Experiences with Hazing in a Male-Dominated Elite Military Institution, 8 Men & Masculinities 470, 475 (2006).

     [86].   See generally Leif J. Braaten, Group Cohesion: A New Multidimensional Model, 15 Group 39, 40–49 (1991) (discussing the conditions of group cohesion including effective orientation, training and contracting, culture building, self-disclosure, and process performance and goal attainment).

     [87].   Mustafa Emirbayer, Useful Durkheim, 14 Socio. Theory 109, 120 (1996).

     [88].   See Braaten, supra note 86, at 39−40.

     [89].   Id. at 44; see also id. at 44–49 (addressing each of the five elements in turn).

     [90].   Id. at 41–42.

     [91].   Id. at 42–44.

[92].   See, e.g., Nancy L. Collins & Lynn Carol Miller, Self-Disclosure and Liking: A Meta-Analytic Review, 116 Psych. Bull. 457, 457 (1994) (“Self-disclosures . . . involve the act of revealing personal information about oneself to another.”).

     [93].   See Hunter A. McAllister, Self-Disclosure and Liking: Effects for Senders and Receivers, 48 J. Personality 409, 415 (1980).

     [94].   Id.

     [95].   Collins & Miller, supra note 92, at 469–70.

     [96].   Id. at 465.

     [97].   Hunter A. McAllister, Self-Disclosure and Liking: Effects for Senders and Receivers, 48 J. Personality  409, 409–10, 415–17 (1980).

     [98].   Id.

     [99].   Id.

   [100].   Id.

   [101].   See Thomas W. Treadwell et al., The Effectiveness of Collaborative Story Building and Telling in Facilitating Group Cohesion in a College Classroom Setting, 61 Int’l J. Grp. Psychotherapy 502, 504 (2011); Albert V. Carron et al., Cohesion and Performance in Sport: A Meta Analysis, 24 J. Sport & Exercise Psych. 168, 170–71 (2002).

   [102].   Richard L. Moreland & John M. Levine, Socialization and Trust in Work Groups, 5 Grp. Processes & Intergroup Relations 185, 189­­–90 (2016).

   [103].   Id. at 186.

   [104].   Id. at 190–93.

   [105].   Encyclopedia of Creativity 449 (Mark A. Runco & Steven R. Pritzker eds., 2d ed. 2011).

   [106].   Yvonne H. M. Van den Berg, Peers in Proximity: New Perspectives on Interpersonal Processes in the Classroom 13 (2015).

   [107].   Id.

   [108].   Jeffrey A. Hall, How Many Hours Does It Take to Make a Friend?, 36 J. Pers. & Soc. Relationships 1287, 1287 (2018).

   [109].   Alexandra Robbins, Why Does Frat Hazing Still Happen? Because Alums Want It to, Medium (Feb. 11, 2019), https://gen.medium.com/why-does-frat-hazing-still-happen-because-alums-want-it-to-801491d6d36d.

   [110].   Alexander, supra note 22, at 67; Feuer, supra note 34, at 68–69 (referencing perceived “skills” members gain by undergoing hazing).

   [111].   Jenny Nirh, Explanations of College Students for Engaging in Hazing Activities 75–76, 98 (2014) (Ph.D. dissertation, University of Arizona).

   [112].   Id. at 76.

   [113].   Id.

   [114].   Id. at 83.

   [115].   Id. at 83–84.

   [116].   Id.

   [117].   Id. at 84.

   [118].   Id.

   [119].   Tresa Mitchell Saxton, The Hazing Practices of Black Fraternities Located on White Campuses: The Interplay of Racism, Masculinity, and Male Violence 9­– 10 (2003) (Ph.D. dissertation, University of North Carolina at Greensboro) (on file with author); Peoples, supra note 17, at 69, 83.

   [120].   Lay, supra note 19, at 79.

   [121].   Id. at 73.

   [122].   See Scott, supra note 19, at 54.

   [123].   Id. at 50–53.

   [124].   Joyce C. Ester, Racial Regard as a Predictor of Hazing Attitudes 68 (2009) (Ph.D. dissertation, University of California, Santa Barbara) (on file with author).

   [125].   Scott, supra note 19, at 54–55.

   [126].   Id. at 54.

   [127].   Id. at 49–51.

   [128].   Id. at 49.

   [129].   Alexander, supra note 22, at 70–72; Massey & Massey, supra note 22, at 57–58; Mathers & Chavez, supra note 22, at 10; Montague et al., supra note 22, at 269. 

   [130].   Alexander, supra note 22, at 69; Deborah Lee Shaw, A National Study of Sorority Hazing Incidents in Selected Land-Grant Institutions of Higher Learning 74 (March 20, 1992) (Ed. D. dissertation, Auburn University) (on file with author).

   [131].   Lay, supra note 19, 84–86; Scott, supra note 19, at 33–34. 

   [132].   Scott, supra note 19, at 48–50. 

   [133].   Peoples, supra note 17, at 65–66.  

   [134].   Caroline F. Keating et al., Going to College and Unpacking Hazing: A Functional Approach to Decrypting Initiation Practices Among Undergraduates, 9 Grp. Dynamics 104, 105 (2005). 

   [135].   See Albert J. Lott & Bernice E. Lott, Group Cohesiveness as Interpersonal Attraction: A Review of Relationships with Antecedent and Consequent Variables, 64 Psychol. Bull. 259, 264–65 (1965); Harry Prapavessis & Albert V. Cannon, Sacrifice, Cohesion, & Conformity to Norms in Sport Teams, 1 Grp. Dynamics 231, 231 (1997).  

   [136].   See Brock Bastian et al., Pain as Social Glue: Shared Pain Increases Cooperation, 25 Ass’n for Psych. Sci. 2079, 2079 (2014). 

   [137].   See John L. Cotton, A Review of Research on Schachter’s Theory of Emotion and the Misattribution of Arousal, 11 Eur. J. Soc. Psych. 365, 366 (1981); Jack Loftis & Lee Ross, Effects of Misattribution of Arousal upon the Acquisition and Extinction of a Conditioned Emotional Response, 30 J. Personality & Soc. Psych. 673, 680 (1974); Stanley Schachter & Jerome E. Singer, Cognitive, Social, and Physiological Determinants of Emotional State, 69 Psych. Rev. 379, 381–82 (1962). 

   [138].   See Nicoleta-Elena Heghes & Cristina G. Schiopu, The Stockholm Syndrome Psychosocial Varieties and Interdisciplinary Implications, in RAIS Conference Proceedings November 66–67, 71 (2019); Keating et al., supra note 135, at 107–08 (discussing how severe treatment stimulates the development of Stockholm syndrome in individuals who are taken hostage). 

   [139].   Montague et al., supra note 22, at 270. 

   [140].   Id.  In contrast, another set of hazers can be grouped as the “fools,” members who do not use common sense when thinking of their positions of power or influence. Id.  A “fool” often has a self-esteem issue or drug and alcohol tendencies, making this type of hazer especially likely to instigate a large amount of physical hazing abuses.  Id.

   [141].   McCreary & Schutts, supra note 56, at 348. 

   [142].   Keating et al., supra note 134, at 105. 

   [143].   Alan D. DeSantis, Inside Greek U.: Fraternities, Sororities, and the Pursuit of Pleasure, Power, and Prestige 6 (2007). 

   [144].   Scott, supra note 19, at 38.

   [145].   See, e.g., id. at 40 (“The majority of [alumni and collegiate BGLF member] participants believe there is no place for hazing in an organization . . . .”).

   [146].   See generally Scott, supra note 19 (presenting findings of a study examining the factors that lead to hazing in BGLFs).

   [147].   Id. at 38.

   [148].   See Alexander, supra note 22, at 67–68; Massey & Massey, supra note 22, at 58; Feuer, supra note 34, at 68–69 (2019) (referencing perceived “skills” members gain by undergoing hazing).

   [149].   Lay, supra note 19, at 82.

   [150].   Lee-Olukoya, supra note 30, at 135.

   [151].   Eranda Jayawickreme et al., Post-traumatic Growth as Positive Personality Change: Challenges, Opportunities, and Recommendations, 89 J. Pers. 145, 146 (2021) (paraphrasing the original Nietzsche quote).

   [152].   Laura E. R. Blackie et al., Post-traumatic Growth as Positive Personality Change: Developing a Measure to Assess Within-person Variability, 69 J. Research Pers. 22, 22 (2017).

   [153].   Richard G. Tedeschi & Lawrence G. Calhoun, TARGET ARTICLE: “Post-Traumatic Growth: Conceptual Foundations and Empirical Evidence”, 15 Psych. Inq. 1, 1 (2004).

   [154].   Eranda Jayawickreme & Laura E.R. Blackie, Post–traumatic Growth as Positive Personality Change: Evidence, Controversies and Future Directions, 28  Euro. J. Pers. 312, 312 (2014).

   [155].   Id. at 314 (addressing researchers P. Alex Linley and Stephen Joseph’s contention that “post-traumatic growth occurs when an individual’s traumatic experience leads to an increase in these specific domains—self-acceptance, purpose in life, environmental mastery, autonomy, and positive relations with others”).

   [156].   Id.

   [157].   Id. at 314.

   [158].   Tamar Blanchard et al., Resilience in the Face of Interpersonal Loss: The Role of Character Strengths 3 (2021), https://iaap-journals.onlinelibrary.wiley.com/doi/epdf/10.1111/aphw.12273.

   [159].   See id. (noting that gratitude and love helped protect against trauma and stress, and the character trait of zest was also significantly related to higher levels of post-traumatic growth following traumatic experiences).

   [160].   See generally id. (discussing research findings indicating higher levels of PTG were found among those with character traits such as self-esteem and individuals who had higher levels of life satisfaction and discussing that life satisfaction was also correlated with lower levels of depression).  

   [161].   Id. (stating that those embodying traits of hope, gratitude, curiosity, love and zest are more likely to respond positively to trauma and loss).

   [162].   Stephen M. Schueller et al., Finding Character Strengths Through Loss: An Extension of Peterson and Seligman (2003), 10 J. Positive Psych. 53, 54 (2015).  It is important to recognize that trauma may negatively impact individuals’ ability to function in everyday life.  See Jayawickreme et al., supra note 152, at 149.

   [163].   Louis D. Brandeis, What Publicity Can Do, Harper’s Wkly., Dec. 20, 1913, at 92, reprinted in Louis D. Brandeis, Other People’s Money and How Bankers Use It (1914).

   [164].   Crimes that Happen While You Sleep, The Sleep Judge, https://www.thesleepjudge.com/crimes-that-happen-while-you-sleep/ (last visited Sept. 25, 2021).

   [165].   Chalfin et al., Urban Labs Univ. of Chicago, Reducing Crime Through Environmental Design: Evidence from a Randomized Experiment of Street Lighting in New York City 17 (2019).

   [166].   Helene Bruckner, Students Fall Victim to Hazing Epidemic: Unity at What Cost?, 34 Touro L. Rev. 459, 482. (2018); see, e.g., Nicholas Bittner, A Hazy Shade of Winter: The Chilling Issues Surrounding Hazing in School Sports and the Litigation That Follows, 23 Jeffrey S. Moorad Sports L. J. 211, 242 (2016) (discussing an example of hazing in sports).

   [167].   Bruckner, supra note 166, at 482 n.197 (citing Elizabeth Allan & Mary Madden, Nat’l Study on Student Hazing, Hazing in View: Students at Risk 24 (2008)).

   [168].   See, e.g., id. at 482 n.195; Gregory Parks & Nicolette DeLorenzo, Hazing in High School Athletics: An Analysis of Victims, 29 Marq. Sports L. Rev. 451, 485 (2019).

   [169].   Susan P. Stuart, Warriors, Machismo, and Jockstraps: Sexually Exploitative Athletic Hazing and Title IX in the Public School Locker Room, 35 W. New Eng. L. Rev. 377, 419 (2013).

   [170].   R. Brian Crow & Scott R. Rosner, Institutional and Organizational Liability for Hazing in Intercollegiate and Professional Team Sports, 76 St. John’s L. Rev. 87, 111 (2002).

   [171].   Dara Aquila Govan, Note, “Hazing Out” the Membership Intake Process in Sororities and Fraternities: Preserving the Integrity of the Pledge Process Versus Addressing Hazing Liability, 53 Rutgers L. Rev. 679, 686 (2001).

   [172].   Parks et al., White Boys Drink, supra note 1, at 141–42; see also Govan, supra note 172, at 687–88.

   [173].   Parks et al., White Boys Drink, supra note 1, at 157.

   [174].   E.g., Kathleen Conn, The Intersection of Hazing, Homophobia, and Title IX in High School Sports, 302 Ed. Law Rep. 12, 20 (2014); Stuart, supra note 170, at 419; Scott R. Rosner & R. Brian Crow, Institutional Liability for Hazing in Interscholastic Sports, 39 Hous. L. Rev. 275, 298 (2002); Jenna MacLachlan, Dangerous Traditions: Hazing Rituals on Campus and University Liability, 26 J. Coll. & Univ. L. 511, 536 (2000).

   [175].   Stuart Rosenberg & Joseph Mosca, Risk Management in College Fraternities: Guidance from Two Faculty Advisors, 9 Contemp. Issues in Educ. Res. 7, 11 (2016) (“Strategies for managing the risk of hazing that have met with success include the monitoring of initiation activities by the faculty advisor and the assurance of transparency in fraternity rituals.”).

   [176].   Stuart, supra note 169, at 421–22; see also id. at 417 (“Without adult supervision and more responsible masculine role models, adolescent self-governance [may take on] the characteristics of a street gang . . . .”).

   [177].   Kristen Peters, Protecting the Millennial College Student, 16 S. Cal. Rev. L. & Soc. Just. 431, 462 (2007).

   [178].   Rosner & Crow, supra note 170, at 295 (quoting Rupp v. Bryant, 417 So. 2d 659, 668–69 (Fla. 1982)).

   [179].   Lawrence E. Cohen & Marcus Felson, Social Change and Crime Rate Trends: A Routine Activity Approach, 44 Am. Socio. Rev. 588, 589 (1979).

   [180].   Id. (quoting Daniel Glaser, Social Deviance 4 (1971)).

   [181].   Id. at 590.

   [182].   Id.

   [183].   Id.

   [184].   Id. at 591.

   [185].   Id.

   [186].   Id. at 590.

   [187].   See generally id. (noting that “guardianship is implicit in everyday life” and includes “guardianship by ordinary citizens of one another and of property as they go about routine activities”).

   [188].   For an analysis of Routine Activities Theory in the context of sexual assault, see generally Amy I. Cass, Routine Activities and Sexual Assault: An Analysis of Individual- and School-Level Factors, 22 Violence & Victims 350 (2007) (providing such an analysis); Elizabeth Ehrhardt Mustaine & Richard Tewksbury, Sexual Assault of College Women: A Feminist Interpretation of a Routine Activities Analysis, 27 Crim. Just. Rev. 89 (2002) (same); Martin D. Schwartz et al., Male Peer Support and a Feminist Routine Activities Theory: Understanding Sexual Assault on the College Campus, 18 Just. Q. 623 (2001) (same).

   [189].   See generally Jane Stapleton & Elizabeth Allan, Lessons Learned from Bystander Intervention Prevention in Ending Sexual and Relationship Violence and Stalking: Translations For Hazing Prevention (2014), https://www.stophazing.org/wp-content/uploads/2014/08/FINAL-lessons_learned-from_bystander-intervention_1_24_14-11.pdf (highlighting several hazing prevention methods).

   [190].   Ann Marie Popp, The Effects of Exposure, Proximity, and Capable Guardians on the Risk of Bullying Victimization, 10 Youth Violence & Juv. Just. 315, 328 (2012) (exploring bullying in the school context); Daniel B. Weddle, Bullying in Schools: The Disconnect Between Empirical Research and Constitutional, Statutory, and Tort Duties to Supervise, 77 Temp. L. Rev. 641, 654 (2004) (same); Ryan Broll & Robin Lafferty, Guardians of the Hallways? School Resource Officers and Bullying, 17 Safer Cmtys. 202, 202–03 (2018) (same); Vincent J. Roscigno et al., Supervisory Bullying, Status Inequalities and Organizational Context, 87 Soc. Forces 1561, 1567–58 (2009) (exploring bullying in the employment context).

   [191].   Weddle, supra note 190, at 656–57.

   [192].   Id. at 657.