Phuong 1 began to experience physical abuse by her husband shortly after they were married; he often beat her when she did not satisfy his demand for sex. Facing economic hardship under the new communist regime that took over South Vietnam at end of the Vietnam War, Phuong and her husband fled the country in 1990, just a few months after their wedding, hoping to find a better life. After arriving in Malaysia, the couple spent seven years in a refugee camp where Phuong gave birth to her daughter. Eventually, they were repatriated because they did not meet the criteria for refugee status. Because the abuse became more and more severe over time, Phuong planned to file for divorce. However, when her husband applied for resettlement in the United States under the Resettlement Opportunities for Vietnamese Returnees (ROVR) program, she decided to remain in the relationship to complete the paperwork for immigration. Her daughter was paralyzed shortly after birth, and Phuong wanted to go to the United States in order to receive better medical treatment and care for her child. Two years later, Phuong, her daughter, and her husband were allowed to resettle in the United States.
Phuong had received little education in Vietnam, and even less training in English in the United States. She did not work and spent most of her time at home taking care of her disabled daughter. When Phuong learned that spousal abuse was prohibited in the United States and supportive services were available for domestic violence victims, she wanted to report the incidents to deter her husband. However, fearing the brutal retaliation that she had experienced several times in the refugee camp, she did not call the police. Because she needed her husband to work and support the family, she did not want him involved with the law. She believed that his arrest would endanger his immigrant status and his employment. Phuong sought help from a women's shelter, but she was not admitted because the shelter could not accommodate her daughter's disability. When the abuse became un-