PMS has not been accepted as a defense in criminal liability in the only reported U.S. case (Lovato v. Irvin). For PMS to be recognized as a defense, there must be general acceptance of the syndrome by the medical community, and there must be a reasonable degree of certainty that the conduct was proximately caused by the disorder. In addition, many feminist groups fear that recognition of PMS would characterize women as endocrinological cripples. England and Canada have recognized PMS as a mitigating factor, and France recognizes it as a form of legal insanity. However, without recognition by the legal, social, and medical communities, PMS will not be recognized as a defense in the United States. 18 references.