 Legal theorist Jane Kim has argued that “rape tolerance” in the United States—evidenced by low rates of arrest, prosecution, and conviction of rapists at the state level—indicates a need for new legal approaches (2012, 273). In her view, “rape should be considered a form of slavery prohibited by the Thirteenth Amendment of the Constitution, allowing for the creation of a federal criminal regime to prosecute and prioritize rape in conjunction with state regimes” (266). She argues that the Thirteenth Amendment was intended to prohibit slavery and involuntary servitude in all of its forms, and that neither the brief duration of many rapes nor concerns about a “slippery slope” warrant excluding rape from its purview. “In order to construct and prosecute rape in a manner consistent with its purported gravity,” Kim contends, “rape must be effectively prosecuted, prohibited, protected against, and abolished under the Thirteenth Amendment” (267).