In her response to Professor Lininger’s piece, Professor Tuerkheimer explores utilizing the doctrine of forfeiture in the wake of the new Confrontation Clause jurisprudence.  While recognizing that state forfeiture statutes provide new tools for the prosecution of domestic violence, Tuerkheimer highlights the importance of recognizing that the crime of battering is unique and, thus, forfeiture can only be properly utilized in this paradigm of courts are sensitive to this reality.