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Page 28 of 42 103 Minn. L. Rev. 844, *899 This basic overview - drawn from a substantial scholarly literature - paints a somewhat contradictory picture. On the one hand, the primary story is one of longstanding underenforcement - a combination of explicit legal policies, practical evidence- gathering and proof challenges, and cultural biases resulted in a notoriously weak response to sexual assaults by state criminal justice systems. On the other hand, there is a story, over the last forty years or so, of wide-ranging success in achieving reforms on several fronts - substantive and procedural law, institutional design, and resource allocation - designed to improve enforcement capacity. In other words, U.S. jurisdictions made substantial progress against an ingrained tradition of underenforcement without turning to any model of enforcement redundancy - federalization, private prosecution, or judicial review. That is more than state justice systems were ever able to do with regard to local government corruption, where the remedy instead was the rise of federal criminal law enforcement. And yet, few seem to consider this reform story a success. !°8 The data on underreporting by victims, low arrest rates by police, and charging rates by prosecutors (along with the rape kit [*900] testing backlog) make it easy to view state criminal justice systems as failing to achieve adequate enforcement responses to sexual assaults despite the scope and gravity of the problem - 124,000 offenses reported to police in 2015, and 431,000 assault reports estimated by the National Crime Victim Survey. 189 This story of reform, its decidedly limited success, and the responses to that record all reveal insights about the prospects for redressing underenforcement through redundancy in this context. Intersecting feminist, victim rights, and rape-law-reform movements have achieved some remarkable reforms through the political process over the last four decades. U.S. criminal justice, like U.S.

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