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In his contribution to a recent UCLA Law Review symposium,'Professor Stephen Garvey introduces and develops the possibility of viewing" punishment as atonement."'2 Garvey describes an" ideal community" in which punishment serves as" a form of secular penance aimed at the expiation of the wrongdoer's guilt and his reconciliation with the victim and the community."'3 Recognizing that the concept of atonement" sounds religious," Garvey insists and sets out to demonstrate that" atonement makes perfectly good sense independent of religion.'" 4 Nevertheless, Garvey acknowledges that" religion is one place where you'll find atonement's roots" and identifies St. Anselm's eleventh century work as an early example of a theological discussion of atonement. 5 In further discussions of" theological atonement," Garvey cites not only