 Culture conflict theory argues that the group with the most power in any society ensures that their values, traditions and behaviors, which Sellin referred to as "conduct norms", are those to which all other members of society are forced to conform, and any actions which conflict with the interests of the dominant group are identified as deviant and/or criminal in nature.Sellin's original ideas continued to be developed throughout the 20th century, most notably by George Vold in the 1950s and Austin Turk in the 1960s, and continue to influence the contemporary debate.The recent work of Gregory J. Howard, Joshua D. Freilich and Graeme R. Newman applies culture conflict theory to the issue of immigrant and minority crime around the world.