Over many decades, domestic violence statistics have consistently revealed that women from a wide variety of backgrounds are victimized, though the rate of victimization varies depending on a woman’s particular characteristics. Despite this consistency, past and present approaches to domestic violence have failed to attend to the diverse realities of victims. Advocates and researchers first devoted their efforts toward conveying the message that while any woman could potentially become a victim of domestic violence, no woman should become a victim. They then focused on creating laws and policies granting victims greater access to the legal system and making the justice system less intimidating to victims. Legal scholars, however, have argued that not all victims have felt successes in these areas uniformly. Among those women are those who have a criminal history (most often property or drug offenses) who encounter unique barriers to reaching out for protection. This manuscript outlines those unique barriers as expressed by women themselves, and makes recommendation for changing the legal system to remove them.