Notes on: Crenshaw, K. (1989) "Demarginalizing the Intersection of Race and Sex: A Black Feminist Critique of Antidiscrimination Doctrine, Feminist Theory and Antiracist Politics," University of Chicago Legal Forum: Vol. 1989: Iss. 1, Article 8. Available at:

There is a tendency to treat race and gender as mutually exclusive categories 'of experience and analysis'(139) and this can be perpetuated by a framework dominant in antidiscrimination law and also feminist theory and antiracist politics. We can see this if we focus on Black women and how they have been theoretically erased. One implication is to see subordination as occurring along a single categorical axis which limits enquiry to the experiences of 'otherwise privileged members of the group' (140) — in race discrimination, in terms of the sex or class privileges of Blacks, in sex discrimination cases, race or class privileged women.

Other members are multiply burdened, however, and suffer from non-discrete sources of discrimination. The usual forms tend to represent only a subset of discrimination. In particular it marginalises Black women in feminist theory and in antiracist politics, because neither accurately reflects the interaction of race and gender. The problem is not to be solved by simply including Black women within 'an already established analytical structure' because the intersectional experience is 'greater than the sum of racism and sexism'. The entire framework has to be rethought and recast.

As examples, we can look how courts frame and interpret the stories of Black women plaintiffs, as part of Black women's experience. Three Title VII cases will be examined [employment discrimination cases it seems, involving individuals taking on companies — General Motors, Hughes Helicopters, and Travenol].

In the first case, five Black women sued General Motors alleging discrimination. GM had not hired Black women at all before 1964, and all those hired after 1970 lost their jobs in a layoff based on seniority. The district court had found for the defendant and rejected the suit brought specifically on behalf of Black women, arguing that there was no grounds to consider them as a special class to be protected from discrimination, to claim some 'super-remedy'. The case would need to state a cause of action for race discrimination or sex discrimination '"but not a combination of both"' (141). GM had hired female employees, 'albeit white women' so they did not practice sex discrimination. The court also dismissed the race discrimination complaint [presumably because GM had hired Black men]. They did not want to allow a new combined category because that would open '"Pandora's box"'. The implication is that discrimination faced by Black women have boundaries set by white women's and Black men's experience, and that they are protected from discrimination only to the extent that their experiences coincide with either of these groups: if they are distinct, they have no protection, and problems of intersectionality are totally obscured.

In the second case, the plaintiff alleged that the employer practised race and sex discrimination in promotions, producing statistical evidence showing that there was a significant disparity between men and women, and, a slightly smaller one between Black and white men when it came to promotion to supervisory jobs. The court decided that the plaintiff had pleaded only discrimination as a Black female, and so this raised doubts about her ability to appear as a class representative, in any sex discrimination proceedings — whether she would '" adequately represent white female employees"' (144). Again this shows an inability to grasp Intersectionality and also the centrality of white female experiences — the implication is that discrimination against Black females is something less than discrimination against females in general — discrimination against Black females does not count as discrimination against females, that the absence of a racial reference means a less inclusive claim. If a white female claims sex discrimination, they do not have to specify their racial identity, 'because their race does not contribute to the disadvantage for which they seek redress… [which]… takes race privileges as a given' (145). Discrimination against white females becomes 'the standard sex discrimination claim', against which Black females appear as some sort of hybrid, less than pure, even though such claims may have 'particularly harsh consequences'.

This case clearly shows limitations of antidiscrimination law and its remedial scope. In effect it 'limits remedial relief to minor adjustments within an established hierarchy' (145) and in effect prevents combining discriminations to challenge an entire employment system, favouring individuals seeking to protect their place within hierarchies, sometimes guarding their advantages 'while jockeying against others to gain more'. Black women are probably 'best able to challenge all forms of discrimination' but are 'essentially isolated and often required to fend for themselves'.

In the second case, the plaintiff was left to defend her case with statistical evidence of discrimination against Black females alone, and the court further limited her ability to do this by letting her include only Black women who 'it determined were qualified to fill the openings' in the upper level jobs. They then decided that the plaintiff had not demonstrated that there were any such Black women. Further, even if they accepted the plaintiff's argument that the percentage of Black women in supervisory positions 'should equal the percentage of Black women in the employee pool, it would still not find discriminatory impact' (146) [Apparently the promotion of only two Black women would have achieved the expected mean distribution of Black women, and this enabled the court to argue that this was not enough to prove that a prima facie case of disparate impact had been proven]. The plaintiff was left with a small sample, so small that she 'could not have shown discrimination under a disparate impact theory'.

In the third case, similar problems arose with the legal problems of winning 'certification as class representatives in some race discrimination actions' (147). The case might suggest significant disparities between Black and white workers, and further disparities between Black men and Black women. Courts are then able to show that sex disparities between Black people create conflicting interests so that Black women cannot possibly represent Black men adequately. This was argued in the third case where two Black female plaintiffs alleged race discrimination and brought a class action on behalf of all Black employees at the pharmaceutical plants. The court refused to allow them to represent Black males and said they could only represent Black women. The court found there had been racial discrimination and found in favour of Black female employees, but refused to extend the remedy for Black men because they had conflicting interests and these would not be adequately addressed.

The plaintiffs in this case were not denied statistics showing the overall pattern of race discrimination, even though there were no men in their class, but they were not allowed to represent all Black employees. It was a partial victory for Black women, but they were still left with the dilemma — whether to articulate their specific interests and risk their ability to represent Black men, or ignore intersectionality in order to state a claim that would include Black men. Overall, 'there is little wonder that many people within the Black community view the specific articulation of Black women's interests as dangerously divisive' (148).

The cases show that several courts have been unable to deal with intersectionality. They refused to recognise compound discrimination, or they have argued that Black women cannot use statistics showing overall sex disparity, or they have argued that Black women cannot represent the entire class of Blacks. Perhaps this is inconsistent criticism, because Black women have been treated differently in different cases, compared to different groups?

This is only 'an apparent contradiction' however (149): Black women can experience discrimination in any number of ways, and their claims of exclusion are not unidirectional. It is like traffic at an intersection coming and going in four directions. Black women can be harmed in the intersection, from sex discrimination or race discrimination. They can experience discrimination that is similar to white women, and sometimes similar to Black men, and often they experienced double discrimination — 'the combined effects of practices which discriminate on the basis of race and on the basis of sex'.  Sometimes discrimination is specific to Black women, not just the sum of race and sex discrimination. It is broader than the general categories, and it will obscure their experience to filter them through these categories.

The 'unique compoundedness' (150) of Black women has been ignored by feminist and civil rights thinkers as well. They have been regarded as too much like women or too much like Blacks, and absorbed and of collective experiences of either groups, or too different from either and thus marginalised. The dominant ways of thinking about discrimination have been uncritically accepted.

For example discrimination in law proceeds from identifying specific classes or categories within which members are disadvantaged by a discriminator, sometimes intentionally: all people within a race or sex category are treated similarly, so any variation within the group suggests that the group is not being discriminated against or that there are conflicting interests, which 'will defeat any attempts to bring a common claim'(151). Categories cannot be combined. Categories become significant only if they disadvantage the victims: 'the privileging of whiteness or maleness is implicit, it is generally not perceived at all'. Discrimination assumes that decisions would otherwise be fair or neutral. There is no commitment to improve substantive conditions for the victimised. There is a commitment only to limited regulation of the process of determining outcomes [I think it's a functionalist assumption that rational outcomes should be left to proceed, as meritocratic and thus fair]. One consequence is that discrimination has come to be defined in terms of the experiences of those who are 'privileged but for their racial or sexual characteristics', which imports the experiences of white women, or the experiences of the most privileged Blacks [best-qualified?]. 'None of which include discrimination against Black women'

Black women can receive protection only if their experiences are similar to those whose experiences are already 'reflected in antidiscrimination doctrine' (152). If they can claim that '"but for" their race' or gender [presumably as single factors?] they would be treated differently, they will be open to protection.  If not they are left unprotected [how on earth can you leave class out of this?]. This is the appropriate framework found in much of feminist theory and some antiracist politics. It affects the view that sexism or racism can only be meaningfully discussed with reference to the lives of the privileged, resulting in politics organised around 'the equation of racism with what happens to the Black middle class [long overdue and still not discussed] or to Black men, and the equation of sexism with what happens to white women'. This appears in the adoption of a single issue framework and the neglect of an adequate theory and praxis to address intersectionality.

Nevertheless, Black women's history has had an important impact on feminist discourse, including the work of a certain Sojourner Truth 'who declared"Ain't I A Woman?"' in 1851. She took on stereotypes of women by men who claimed they were too frail to be involved in political activity. She recounted the horrors of slavery and showed the effects on her body. There was a challenge to white feminists involved as well. That challenge needs to be renewed to feminists who claim to speak for all women but do not address Black ones, using 'the authoritative universal voice' (154) usually found in a form of 'white male subjectivity' as well, but appearing in feminist theory that 'remains white'.

An example would be the 'separate spheres literature' central to feminist legal thought. This argues that men and women have traditionally had unequal separate societal roles, but it offers little insight into Black women and their particular form of domination, and has led to overgeneralised and 'often wrong' statements referring to Black women [a note further accuses Friedan's The Feminine Mystique of placing white middle-class problems at the centre of feminism and explains hooks' rejection of it]. For example, 'Black men are not viewed as powerful, nor are Black women seen as passive'(155), because there are 'crosscutting forces' to establish gender norms. There have even been 'those in the Black liberation movement to aspire to create institutions and to build traditions that are intentionally patriarchal' (156) [hooks Ain't I a Woman is cited again here]. Ideological definitions of patriarchy are 'usually premised upon white female experiences' and feminists often make the mistake of assuming that 'since the role of Black women in the family and in other Black institutions does not always resemble the familiar manifestations of patriarchy… Black women are somehow exempt from patriarchal norms'. For example, Black women have traditionally worked outside the home far more than white women  [middle class ones] and so have been burdened by a particular gender-based expectation, and have often experienced conflict with more traditional feminine norms involving personal,emotional relationships — another aspect of Intersectionality.

Feminist discourse on rape has involved an historical critique of the role that the law has played, arguing that its main function has been to maintain 'a property like interest in female chastity' (157). However this is 'for Black women and oversimplified accounts and an ultimately inadequate account' because these laws ultimately reflect 'white male regulation of white female sexuality' and there's been no institutional attempt to regulate Black female chastity – Black women were not until recently expected to be chaste. While a fallen white woman's chastity could be restored if the assailant was a Black man, 'no such restoration was available to Black women'(158). Rape was also specifically used 'as a weapon of racial terror' — Black women specifically were being denied any protection especially as the judicial system made 'the successful conviction of a white man for raping a Black woman… Virtually unthinkable' (159). The protection of white female sexuality was often a pretext for terrorising the Black community.

Again there were a distinct set of issues confronting Black women, seldom explored in feminist literature nor prominent in antiracist politics, certainly not compared to the lynching of Black males. There is little interest from a 'Black community that, perhaps understandably, views this suspicion attempts to litigate questions of sexual violence', and a feminist community that focuses on white female sexuality. [Discussed in her second article below].

A 19th-century Black feminist often criticised Black leaders failing to speak for Black women. Crenshaw adds a personal experience about two Black male friends joining an exclusive men's club at law school and inviting her to a celebration, only to find that she could not be admitted through the front door because she was a female — everyone was congratulating themselves because she was a Black person and that was  OK. It shows that enjoyment of privileges have been won on the basis of race but not on the basis of sex, as well as a certain ambivalence among Black women about the extent to which gender barriers should be challenged especially if they conflict with the antiracism agenda: some still see race as the central oppositional force, a primary group identity.

However gender subordination is a significant contributor 'to the destitute conditions of so many African-Americans' (162). The politics of racial otherness has prevented Black feminist consciousness having much impact on white feminism. White women have been able to develop much more of an opposition to white men, but Black women live in the community that has been defined and subordinated by both colour and culture and this makes 'the creation of a political consciousness that is oppositional to Black men difficult'. Nevertheless, 'the assertion of racial community' sometimes marginalises Black women and peripheralises them, as in the controversy over the film The Colour  Purple  and the way it portrayed domestic abuse [discussed in the other article — whether or not this confirmed racial stereotypes about Black men].

Moynihan once diagnosed the ills of Black America in terms of the deteriorating Black family and the emergence of the Black matriarch. Many critics saw it as racist, but few noticed its sexism in labelling Black women as pathological because they did not live up to a white female standard of motherhood. These stereotypes can still be found in recent documentaries about female-headed households as involving 'irresponsible sexuality' (164) sometimes encouraged by the welfare state making the role of Black men obsolete. Critics focused on racism but there were sexist assumptions as well, but even white feminists did not respond. It is still common to see female-headed households as dysfunctional, even if one program blamed the economic structure for not providing Black men with suitable jobs. However, the choices of Black women might also be maximised and there are specific and particular concerns addressed when it comes to managing their lives and families.

Any proper attempt to address racial subordination must include an analysis of sexism and patriarchy, and feminism must include an analysis of race. Intersectional experiences are essential, and earlier approaches must be abandoned if they focus only on 'certain clearly identifiable causes — the oppression of Blacks on race, women based on gender. Instead, 'the praxis of both should be centred on the life chances and life situations of people who should be cared about without regard to the source of the difficulties' (166). Compoundedness should be addressed in all its complexity in both politics and new thinking. It's not helped by top-down approaches to discrimination. We need bottom-up approaches instead of starting with the needs and problems of those who are most disadvantaged, those who are most marginalised. We should resist efforts to 'compartmentalise experiences and undermine potential collective action'(167). There is no need to believe that a political consensus will happen tomorrow, but an effort would challenge the prevailing conceptions and the complacency that accompanies them. We would become critical of the dominant view and think of more unifying activity to include marginalised groups.

Notes on: Crenshaw, K. (1995) Mapping the Margins: Intersectionality, Identity Politics, and Violence Against Women of Colour. In Kimberlé Crenshaw, Neil Gotanda, Gary Peller, Kendall Thomas (Eds) Critical Race Theory. The key writings that formed the movement. New York: The New Press: 357 – 83.

Dave Harris

Women have recently organised against violence against women as part of a system of domination 'that affect women as a class' (357), not something isolated and individual, and the same goes for the identity politics of African-Americans gaze lesbians and other POC. However, identity politics are usually seen by mainstream liberals as the remains of bias or domination, 'intrinsically negative' where social power has excluded or marginalised those who are different. As a result, liberation should involve reducing the significance of these categories. However, such categories can also be 'the source of social empowerment and reconstruction'.

One problem is that 'intragroup differences' are often conflated or ignored. For example the violence that many women experience is often shaped by other dimensions such as race and class. Ignoring these differences increases tension among groups which affects efforts to politicise violence against women. Feminist efforts to politicise experiences of women and antiracist efforts to politicise experiences of POC sometimes appear to operate on mutually exclusive terrains even though racism and sexism often intersect in real lives. However, the two dimensions can overlap and intersect, and this is not represented adequately in either separate discourse — 'WOC are marginalised within both' (358).

Intersectionality also affects Black women's employment experiences as she has argued before. They also affect violence against WOC. Intersectionality is not, however, a 'new totalising theory of identity', nor are race and gender the only frameworks — there are multiple grounds of identity.

A field study of battered women in shelters in Los Angeles revealed deeper aspects of subordination, like unemployment and poverty and other forms of domination such as racially discriminatory employment and housing, unemployment. Intervention strategies 'based solely on the experiences of women who do not share the same class or race backgrounds' are often of limited help as expressed in legislation such as marriage fraud provisions of various US Acts designed to protect immigrant women married to US citizens [immigrant women were prepared to accept abuse rather than have their marriage rendered invalid]. Language barriers are another problem [these look rather special to immigrants, although of course immigrants are quite likely to be WOC].

There is political Intersectionality in that WOC often belong to 2 groups pursuing conflicting political agendas and this is not the case often for men of colour and white women. Men of colour tend to determine the overall limits of antiracist strategies, as do white women with sexism, and the other categories are seen as additional. Overall, feminism has failed to interrogate race and so their 'resistance strategies will often replicate and reinforce the subordination of POC' while 'the failure of antiracism to interrogate patriarchy means that antiracism will frequently reproduce the subordination of women' (360). This provides particularly difficult political dilemma for WOC.

This is confirmed by her own experience attempting to review LAPD statistics on domestic violence. The LAPD would not release the statistics, partly because they might show that domestic violence in minority communities might be selectively interpreted and publicised and this might cause political problems for the LAPD or allow opponents to dismiss domestic violence as a minority problem only — some minority communities opposed the release of the statistics themselves as confirming existing stereotypes of Black men as violent. The whole episode shows 'how women of colour can be erased by the strategic silences of antiracism and feminism' (361).

Efforts to stop the politicisation of domestic violence can be grounded in 'attempt to maintain the integrity of the community'. Sometimes feminism is seen as divisive in communities of colour, 'the migration of white women's concerns'. This has been embraced by a Black woman writer [Shahrazad Ali], who sees 'a positive correlation between domestic violence and the liberation of African-Americans… the deteriorating conditions within the Black community [is blamed on] the insubordination of Black women and the failure of Black men to control them', and she advises Black men 'to physically chastise Black women when they are "disrespectful"', sometimes with physical force although only moderately. Patriarchy is beneficial for the Black community.

Of course, there are dangers. 'Nearly 40% of all homeless women and children fled violence in the home, and an estimated 63% of young men… who are imprisoned for homicide have killed their mother's batterers' [Black?]. Overall, 'patriarchal ideas about gender and power preclude the recognition of domestic violence as yet another compelling form of Black on Black crime'.

It's more common that the interests of the community are seen as preventing full recognition of the problem of domestic violence. White Americans are far from coming to terms with violence in their homes, but 'race adds... another dimension to suppression of the problem'. There is a danger of reinforcing distorted public perceptions, but also the need to address problems. The controversy over the novel The Color Purple, with its portrayal of gender violence shows the problems — one critic saw the abused Black woman hero as inauthentic. Violence by Black and other minorities is often portrayed as dominant, without 'a full range of Black experience', but suppressing in the name of antiracism 'imposes real costs' (362).

Some agencies trying to support WOC have reported resistance from their communities, even suppression of violence in the name of 'saving the honour of the family from shame — a matter of 'obliging women not to scream rather than obliging men not to hit'. WOC are often reluctant to call the police, understandably if the police are seen as hostile, and to involve public intervention, to remain private, an understandable reaction from 'racially subordinated people'.

Sometimes, violence against WOC is seen as 'just another manifestation of racism', a 'consequence of discrimination against men'. No doubt it does contribute to the cycle of violence and places men of colour under stress, but there is a more complex chain of violence. Racism is linked to patriarchy, by denying Black men power and privilege that white men enjoy. Violence can be seen as a resultant 'acting out', but suggesting this is linked to domestic violence as a solution is 'counter-productive': better to 'challenge the legitimacy of such power expectations by exposing their dysfunctional and debilitating effect on families and communities of colour'. Nor should WOC have to wait for protection from violence until the ultimate triumph over racism.

Feminist concerns often 'suppress minority experiences' (363) by suggesting that battering is a minority problem, rarer in the white community, rather than common in all classes and races – hence the claim in many campaigns that battering is a common problem, not confined to the Other. Nor is violence confined to the streets of cities. Sympathy for victims of domestic violence is still easier for someone from the same race, however, and nonwhite women are still Othered [she draws attention to a TV documentary which humanised the white participants but not the single Black one — she was still 'relegated to the margin of experience' (364)].

Official policies toward domestic violence have sometimes 'reproduced the subordination and marginalisation of WOC' in their policies priorities or strategies, even in their choice of allies. Support services are often literally unavailable for non-English-speaking women [again the slide to a special case?]. Sometimes, offices are located in areas where few POC live, and recruit few WOC. Again sometimes there are differences over definitions of feminism, with an example where 'the board decided to hire a Latina staff person… But the white members of the hiring committee rejected candidates… Who did not have recognised feminist credentials' (366). There are tensions between community-based organisations and official ones.

There is an Intersectionality issue in the context of rape. Dominant conceptualisations are often both racist and sexist, and Black women are situated within both minority groups. That has been politically useful to Black women, but they have sometimes faced 'a political discourse that disserves Black women'(367). One problem is that the dominant stereotype of rape involved a Black offender and a white victim and this has left Black men subject to particular levels of violence including efforts to control and discipline the Black community. Feminists have attacked either patriarchy or conceptions of rape, some of them represented through law, especially the notion of a woman's chastity as property and and negative attitude to those women who had devalued their chastity in some way — an attempt 'to legitimise a good/bad woman dichotomy'. Most of those discriminatory laws have been eradicated, but there are still constructions of rape in popular discourse and in criminal law that 'continue to manifest vestiges of these racist and sexist themes'.

One case involved a white female jogger raped in New York's Central Park and the public discourse mixed together sexual victimisation and rhetoric racism — the rapists were dehumanised as savages and beasts, and pervasive fears about Black men were inflamed. Similar coverage raised echoes of earlier lynchings and led to Trump demanding a return of the death penalty. There were other media spectacles involving gender-based stereotypes, including an acquittal of a man accused of a brutal rape because the jury thought that the woman was asking for sex by the way she was dressed (368), and other cases involved questioning the sexual history of the accuser.

These are all examples of historical rape narratives dating from times when race and sex hierarchies were more explicit. Black women were then devalued and marginalised as sexual victims. In the week that the jogger was raped, '28 other cases of rape or attempted rape were reported in New York. Many… were as horrific… yet all were virtually ignored by the media… [Horrific details follow]… Most of the other forgotten victims that week [were] WOC'.

There still seems to be a sexual hierarchy. This might still be significant in evaluating attitudes towards rape, even in affecting average prison terms, or in the rates at which victims of rape are likely to be believed. There seems to be evidence that 'neither the antirape nor the antiracist political agenda has focused on the Black rape victim'. This is because racism is generally not problematized in feminism, and sexism not problematized in antiracism which means that 'the plight of Black women is relegated to a secondary importance' in both.

Feminist critiques of rape have focused on rape law and the regulation of the sexuality of women, definitions of rape, evidentiary rules and so on, including former rules that there should have been resistance for rape to have occurred, or the problem of weighing the credibility of women against normative standards of female behaviour, or examining sexual history and past sexual conduct. Fundamental reform measures have resulted, but there are still 'pre-existing social constructs that distinguish victims from non-victims on the basis of their sexual character' (369) and these still 'undermined the credibility of Black women'. Their devaluation has not been so centrally addressed, because gender expectations in their case have intersected with 'certain sexualised notions of race… That are deeply entrenched in American culture'.

Sexualised images go all the way back to 1st engagements with Africans. Blacks are more sexual, more interested in gratification, 'bad', discredited, essentially sexual and so on. There needs to be political resources addressing the sexual oppression of Black women specifically, and antirape activists have not done this but have ignored the consequences of racism and the racial dimensions.

By contrast, antiracist criticisms of rape have looked at how the law focuses on rapes of white women by Black men and thus discriminates against Black men. This devalues Black women as well, however. Of course, these accusations have been an historical justification for white terrorism, leading to practices like lynching, even though rape was not always necessarily alleged: it was really a 'well-developed fear of Black sexuality' (370) that led to racial terrorism to keep Blacks under control. The rape of Black women is a dramatisation of racism but 'is usually cast as an assault on Black manhood, demonstrating his inability to protect Black women', not so much an assault on the Black community.

We can still see this kind of sexual politics today, as in the Mike Tyson rape trial, for example. Support for Tyson involved antiracist rhetoric where rape accusations against Black men operated through a male centred frame. The experiences of Black women were hardly mentioned. Racial solidarity meant supporting Tyson, but not the Black woman who accused him. It is common that Black women who claim rape against Black men are frequently 'not only disregarded but sometimes villified within the African-American community'. Statistics apparently show that 'Black women are more likely to be raped than Black men are to be falsely accused of it', yet they get little sympathy if the rapist is Black. In the Tyson case, a common reaction was that the victim asked for it, or that the threat of sexual assault was a routine hazard, and Black women in particular showed the usual 'general resistance to explicitly feminist analysis' (371) when it opposed the long-standing narrative that saw Black men as the primary victim of sexual racism.

Social science studies also classically fail to see how racism and sexism converge. One study of rape prosecutions, for example, showed first that Black defendants face significant racial discrimination, and secondly that rape laws regulate the sexual conduct of women by taking into account their 'nontraditional behaviour' — and yet Black women still fell through the cracks. The study did show that Black offenders who raped Black women were treated more leniently, the reverse if white women were assaulted, but Black rape victims were not considered, even though it is apparent that they are relatively subordinate in a hierarchy to white women, almost implying that they can be raped with relative impunity. In the analysis, they 'become merely the means by which discrimination against Black men can be recognised' (372). It is not just that white men raping Black women are treated leniently — so  are Black men raping them, and this is not seen as so serious because it doesn't seem to be raising issues of racism. Apparently, this marginalisation of Black women by sexism as well is 'replicated in social science research' — they are already less valuable objects before they are subjected to racist subordination. The problem is in the two track framework, with the tracks tested separately [the specific study is further examined]. One particular consequence is to ignore evidence like that 'many cases involving Black women are dismissed outright. Over 20% of rape complaints were recently dismissed as "unfounded" by the Oakland Police Department, which did not even to interview many, if not most of the women involved… The vast majority of the complainants are Black and poor' (374): the police said '"those cases were hopelessly tainted by women who are transient, uncooperative, untruthful or not credible as witnesses"'.

Race and gender actually converge 'in ways that are only vaguely understood' although the analytic frameworks focus on single issues. Cultural images are important and may explain 'social and cultural devaluation of WOC' operating behind political agendas. Grasping these will help 'apply and evaluate the usefulness of the intersectional critique'.

Overall intersectionality helps frame different interactions of race and gender in the context of violence against WOC. It can also help mediate tensions between assertions of multiple identity and the necessity of group politics. Intersectionality is not the same as anti-essentialism, the basis upon which WOC have criticised white feminism for ignoring WOC while speaking for them. Feminism is alleged to have a centralised the category of woman, and this has been criticised by post modernism on the grounds that the categories socially constructed. This post-modern critique is generally sound, although social construction is sometimes missed red. One version of anti-essentialism, the 'vulgarized social construction thesis' denies that there are any categories that are not socially constructed, including things such as 'Blacks or women' and so there is no point organising around these categories. Even the Supreme Court has tried this out by arguing that in a recent case a policy designed to increase the voices of minorities on the airwaves was racist in assuming that 'skin colour is in some way connected to the likely content of one's broadcast' (375): they used a rhetoric that 'oozes vulgar constructionist smugness'.

Even if a categoriy is socially constructed, it can still have significance, especially in thinking about the way power clusters around some categories and is exercised against others, how subordination works and how its processes are experienced by the subordinated and the privileged. The point is not to debate the existence of categories, but 'the particular values attached to them and the way those values foster and create social hierarchies'. Of course the process of categorisation is an exercise of power itself, in the case of identity, a process of naming. It's not unilateral because of the subordinated can participate, sometimes subvert the naming process, as in historical subversion is of categories like Black or queer. There is unequal power but some degree of agency nevertheless. There's usually resistance as well, and flawed terms can become matters of self identification and celebration. A 'strong case can be made' that the best resistance strategy is to occupy a politics of social location and transform it.

Meaningful identity politics is not attacked by vulgar constructionism. Categories have social and material consequences and thus political implications. The history of racial subordination shows it was possible to challenge both the construction of identity and the system of subordination based on categorisation was up for challenge and so was the subordination of people who are labelled — who was considered to be Black, and what would happen to regulate the activities of Black and white people. Lawyers made both arguments, appealing against fixed categories of race, especially as a dichotomy, and subsequently against a strategy of segregation. This apparently famous case provides lessons for resistance today in terms of which would have been best to focus on.

The same goes for Brown versus Board of Education. There were two arguments: segregation was unconstitutional because the racial categorisation system was incoherent, and segregation was unconstitutional because it was injurious to Black kids. Mostly the question has been discussed in terms of the second issue. The issue of categorising, defining identities has largely been secondary. It is important to examine this gap between separated dimensions of race and gender, and the dangers of essentialising Blackness and womanhood. The problems are not linguistic or philosophical but political. The narratives of gender are 'based on the experience of white middle-class women, and the narratives of race are based on the experience of Black men' (376) The point is to identify which aspects of specific cases have been erased by the circumstances.

We should recognise the existing identity groups which are politically active as coalitions, and reconsider them — for example as coalitions between men and women of colour. We should drop any idea that WOC should abandon an existing agreement that the interests of the community require the suppression of discussion of intra-racial rape or any other marginalisations. This will involve energy and may arouse 'intense anxiety' (377). We will have to oppose 'internal exclusions and marginalisations' and 'call attention to how the identity of "the group" has been centred on the intersectional identities of a few'. Focusing on where categories intersect seems more fruitful than just talking about categories: it helps acknowledge and ground differences among us and negotiate the ways to express these differences and construct adequate group politics.

Some of the asides and notes in this later article are absolutely astounding. For example, Crenshaw cites the work of Shahrazad Ali (1989) The Blackman's Guide to Understanding the Blackwoman, which is apparently notorious although I had never heard of it. It is 'stridently antifeminist' and 'draws a positive correlation between domestic violence and the liberation of African – Americans. The insubordination of black women and the failure of black men to control them is blamed for the conditions inside the black community and black men are advised to 'physically chastise black women when they are "disrespectful"" (361). In the considerable publicity that accompanied the work, which included appearances on famous talkshows and considerable press reaction, it emerged that Miles Davies had admitted in his autobiography that 'he had physically abused, among other women, his former wife, actress Cicely Tyson' (379).


Note 17 says that Ali 'advises the black man to hit the black woman in the mouth "because it is from that hole, in the lower part of her face, that all her rebellion culminates into words. Her unbridled tongue is a main reason she cannot get along with the black man"'.


Note 18 says there are similarities with the neoconservatives who also blame the breakdown of patriarchy or family values for the ills affecting America, including the Moynihan Report which blames a matriarchal structure emerging in the Negro community. This was partly supported by Lyndon B. Johnson and led to proposals to overhaul the social welfare system.


Later, addressing the ambivalence in the black community towards rape, note 23 says that Eldridge Cleaver 'argued that he raped white women as an assault upon the white community. Cleaver "practised" on black women first'[in his book Soul on Ice 14 – 15]. Nevertheless, he was still able to worship black women as '"Queens of the black community"'. Note 41 describes a hoax rape allegation which attracted a lot of attention in a student newspaper. Note 42 details the role of Donald Trump who felt that muggers and rapists should be subject to capital punishment [although he was not in government at the time].