d women. This new issue led Del Martin to publish Battered Wives in 1976, the first piece written about battered women in the U.S. Although the research on battered women had just begun, many American courtrooms began dealing with these relatively new cases involving women as early as 1977. The famous case of State v. Wanrow (1977), resulted in the Washington State Supreme Court declaring the need for a more gender-based self-defense test. This case led to a greater approval of battered women's issues among the public and sparked renewed interest in psychological research (Downs pg. 77). Battered Women's Syndrome, although originating in part from the oppression of women, was initially developed by psychologists to help explain the behavior of women who were exposed to frequent and continuous abuse. The most highly recognized in the field of BWS, is psychologist Dr. Lenore Walker. Walker has dedicated most of her life to studying battered women and their victimization. Using the psychological theory of "learned helplessness," Dr. Walker came up with her own hypothesis to explain why battered women behave the way they do (Dubin pg. 9). Walker's findings resulted in the theory known as the "cycle of violence" (Downs pg. 76). The cycle portrays three distinct phases in which battered women go through with their abusers. Phase One is known as the "tension building phase." In this phase the woman senses that her partner is becoming increasingly sensitive to very minor disturbances. Phase Two is known as the "explosion phase." The male partner, in this phase, physically and emotionally abuses the woman. Phase two can last for minutes or hours, depending on the situation. Phase Three is known as the "calm or loving phase," and is thought to be why most women stay with their abusers. In this phase, the man apologizes repeatedly and promises to never hurt the woman again. After all the phases are complete, the woman believes h...