It is now somewhat trite to observe that feminist theory, in the legal realm as elsewhere, suffers from a certain element of so-called "essentialism." What is meant by this, partly, is that feminism has mistakenly posited a "universalized" woman, for whom gender is her primary determinant, and whose experience "as a woman" is somehow untouched by other forces of systemic subordination, such a racism, classism, heterosexism, and ablism. Having not alerted itself to the potential differences that other systemic forces of subordination might make in women's lives, feminism has tended to draw its theoretical conclusions from the experience of the privileged few among the female class. In itself this would not necessarily be troublesome, were it not for the fact feminism tended not to notice that was what it was doing. The result, so goes the critique, has been the formulation of feminist theory which is partial, in the sense that its assumed but unarticulated position has been that of the white, heterosexual, middle-class, and able-bodied female, and which is consequently unresponsive to the "difference" made by differences of race, class, sexual orientation, and the like (Harris 1990; Spelman 1988; Crenshaw 1989; Kline 1989).