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<html><head> <title>DID/MPD Legal Defense ~ Multiple Personality Disorder in the Courts, by Dr David James</title> <LINK REL="SHORTCUT ICON" HREF="http://www.astraeasweb.net/images/astraea-undosa.ico"> <META HTTP-EQUIV="expires" CONTENT="Now"> <meta name="keywords" content="multiple-personality, multiple, personalities, personality, MPD, MPD/DID, abuse, alien, alienated, Allucquere, alternative, dissociate, dissociative, empower, extraterrestrial, liberation, freedom, goth, Milligan, minority, unorthodox, strange, witches, unexplained, magick, creativity, creative, imagination, otherkin, protection, praise, psychedelic, radio, recognition, Schreiber, Sybil, television, transpersonal, Wilbur"> <body bgcolor="#b7005b" background="http://www.astraeasweb.net/images/grntiedye.jpg" text="660000" link="#7d26cd" vlink="#808040"> <center><table width=80% cellspacing=20 cellpadding=20> <tr> <td width=65% bgcolor="#ffffe1" text="white"> <h2 align="center"> MULTIPLE PERSONALITY DISORDER IN THE COURTS: A REVIEW OF THE NORTH AMERICAN EXPERIENCE</h2> Dr. David V. James MA, MRCPsych Senior Lecturer in Forensic Psychiatry University Department of Psychiatry Royal Free Hospital School of Medicine Rowland Hill Street London NW3 2PF ABSTRACT Multiple personality disorder has increasingly been encountered in the forensic setting in north America over the past twenty years, in particular in relation to competency hearings and insanity defences. The particular legal problems that have arisen are reviewed, the most significant U.S. cases and judicial decisions are explored, and their implications for issues of responsibility, individuality and punishment are discussed. (Abstract word count = 60) Keywords: multiple personality disorder, dissociation, insanity, fitness to plead, responsibility, punishment. Over the last thirty years, the diagnosis of multiple personality disorder (MPD or MPS) has been made with increasing frequency in the USA and Canada (Boor, 1992; Freeland et al., 1993), where it has been estimated to be "roughly as common as schizophrenia" (Ross, 1997). Although many psychiatrists remain deeply sceptical about the phenomenon (French & Shechmeister, 1983; Lewis & Bard, 1991; Dinwiddie et al., 1993; Saks, 1994), its inclusion in DSM III (American Psychiatric Association, 1980) in 1980 as a distinct clinical entity both reflected its acceptance by a section of American psychiatric opinion, and encouraged the identification of further "cases" (Halleck, 1990). With the publication of autobiographical and other accounts of MPD sufferers (e.g. Thigpen & Cleckley, 1957; Schreiber, 1973; Hawksworth & Schwartz, 1977; Keyes, 1981; The Troops for Truddi Chase, 1987; Casey, 1991), MPD has been absorbed into the popular consciousness. With thousands of cases diagnosed and proponents publishing large personal series (Bliss, 1980; Bliss & Jeppsen, 1985; Putnam et al., 1986; Coons et al., 1988; Ross et al., 1989; Ross et al., 1990), it has inevitably entered the courtroom and into the practice of forensic psychiatrists and psychologists (Slovenko, 1993). Courts have recognised so-called "alter" personalities as having separate existences for the purposes of sworn testimony (Allison, 1982; Slovenko, 1989; Perr, 1991). Alters have asked for separate legal representation (French & Shechmeister, 1983). MPD has resulted in acquittals in cases of forgery (Allison, 1982) and rape (Perr, 1991). It has been presented as evidence of incompetency (unfitness to plead) (Saks, 1994), on occasion with success in murder cases (Coons, 1991). It has formed the basis of successful insanity pleas in cases of rape (Keyes, 1981) and murder (Allison, 1982; Perr, 1991). Defendants have malingered MPD (Abrams, 1983; Orne et al., 1984; Coons, 1991). The disorder has been the subject of at least one civil malpractice suit for wrongful (positive) diagnosis (Serban, 1992), and conversely it has been argued that clinicians face legal jeopardy if they fail to diagnose MPD in patients "with the condition" (Hardy et al, 1988). This use of MPD in the court-room has aroused concern about its implications for the attribution of moral, legal and criminal responsibility, and raised fundamental questions about individuality, "personhood", and the justification for punishment (Gillett, 1986; Slovenko, 1989; Halleck, 1990; Saks, 1992; Slovenko, 1993; Beahrs, 1994; Saks, 1997). The US experience and the particular difficulties that have confronted US courts are examined in detail below. 1) The right to legal representation French and Shechmeister (1983) report a Californian case, where an "alter" specifically requested separate representation. The authors acknowledge that his interests were substantially different to those of the other personality "present" and, as such, to represent both might present a conflict of interests. They could find no basis in law for the exclusion of the second personality as a representable entity. Their casual survey of local defence attorneys suggested that a second personality could readily obtain such representation, initially at least, provided that he presented himself in the proper manner. The authors concluded that "any personality presenting itself for representation before diagnosis of MPS may gain at least initial representation, but once a diagnosis of MPS has been established, the socially identified primary personality will be represented and all others will be ignored as symptoms of illness". 2) Allowing different personalities to give evidence at court It is a small step from individual representation to accepting the existence of individual entities, and to allowing different alters to give evidence in court. In the USA, it would appear that it is neither a particularly rare, nor recent phenomenon for different "alters" to be allowed to testify. Allison (1982) reports a number of cases from his own practice. In one case, two pleasant personalities were "brought out" in court in a man whose "bad personality" had been arrested for drunken driving. The man then published an autobiography (Hawksworth & Schwarz, 1977). In another case, that of Anthony J., Allison had discovered two alters, "John Grace", a vulgar man who admitted to the assault and robbery of a doctor's wife, which formed the substance of the case, and "Alexander", a "rescuer", who supplied the attorney with all the information that Anthony J. and John Grace "did not have". John Grace managed to escape from the courthouse, but was later recaptured, an incident of which Anthony J. had "no memory". At the trial, Anthony J. took the stand and testified that he did not remember committing the crimes charged. Then at the attorney's request, John Grace "came out to testify how he had committed the crimes, throwing in snide, nasty comments at the judge and the district attorney along the way". Having waived jury trial, Anthony J. was found guilty on all counts by the judge. Allison expresses concern that John Grace might put Anthony J. at risk by antagonising his gaolers. His conclusion from the case is that, if multiple personalities are being sent to gaol, then "some adequate treatment must be found in prison". The giving of evidence in court by different alters, and the implicit acceptance that individual personalities can exist as autonomous entities within an individual person, can result in ever more complicated tangles of confusion about the attribution of moral and legal responsibility and can lead to laughable scenes at court (Halleck, 1988). A defining case of the legal and procedural difficulties that can arise is that of the State of Wisconsin v. Mark A. Peterson in 1990, when six of the supposed 47 personalities of a female witness were sworn in separately. The 26 year-old Sarah complained that two of her personalities, a child and an adult, had been raped by Peterson, a 29-year-old grocery worker. It was alleged that Peterson had made friends with another 26-year-old personality, called "Franny". He had then been instrumental in calling forth "Jennifer", a 20-year-old personality, who, according to Franny, "liked to dance and have fun". Peterson and Jennifer then had sex in the back of his car. During intercourse, another personality suddenly intruded, that of a six-year old named Emily. Peterson allegedly told Jennifer to tell Emily to keep their activities "a secret". Instead, Franny and Emily "told" Sarah, the "predominant personality", who made a complaint to the police. Neither Franny, nor Emily, nor Sarah was said to have consented to sexual intercourse. After a one day pre- trial hearing (Slovenko, 1989; Los Angeles Times, 1990; Saks, 1994), the main trial attracted national media attention (Time Inc. Magazine Company and Compact Almanac, 1990; Washington Post, 1990a; Washington Post, 1990b). When Sarah, the complainant took the witness stand, the District Attorney summoned in turn a number of her personalities. At one point, the prosecutor and the judge later recalled, she switched briefly into the personality of a dog (New York Times, 1994).The judge required the woman to take an oath each time that she changed personality, and the lawyers formally introduced themselves to each different personality. The District Attorney began with Franny, who talked of meeting Peterson in a coffee shop, and telling him in conversation of her unusual affliction. "I recall telling him that there were many of us in the body". Franny remembered him asking to meet Jennifer, but had "no personal knowledge" of what happened after that, because she hadn't been present. The district attorney then called forth Jennifer, who waved at the jury, shouting "Hi!" in a voice different to that of Sarah or Franny. Several jurors lifted their hands to wave back. Jennifer described in detail the sexual act in which she had agreed to engage, with (apparently) no understanding of what had been going on. Asked by the defending attorney: "Didn't the two of you have sex?". She replied: "I dunno. What's sex?" Jennifer did however reveal that she had at some point undergone a tubal ligation. Jennifer denied being a multiple personality or being in treatment with a therapist or giving such information to Peterson. The district attorney suggested to the jury that it was obvious that none of the individual personalities had a mental illness; they were a mental illness. The defence attorney made motions in the absence of the jury, reasoning that his client had sex with Jennifer, that Jennifer was "in touch with reality", and that, even if Sarah didn't know what she was doing in the front seat of Peterson's car, Jennifer did. Peterson then testified that he thought he was having sex with Franny. He stated that he did not know she was ill, but thought she was "a possible promiscuous person", (a statement that acquired new meaning in the light of the number of personalities allegedly involved in, or at least in "the body" at the time of, the sexual act). The prosecution introduced psychiatrists who testified that Sarah was suffering from multiple personality disorder, with the number of alter personalities varying from eighteen to forty-six, some of which were "fragments", carrying only certain emotions. Sarah's therapist related to the court that Emily, the six-year old victim, sometimes ate crayons which the other personalities then had to spit out. The judge at the outset cautioned those in court that the case was a sensitive one and "not a circus". Events suggested otherwise. Spectators queued from the early hours for a seat in court, and folding chairs had been brought into the courtroom in order to increase its capacity. The judge had to warn the audience that those leaving to go to the "bathroom" were likely to find that they had lost their places upon their return. The District Attorney screened his jury pool by asking for a show of hands from those who thought the case too bizarre to contemplate. "You will get the chance to observe her transform from one personality to another", he said. "It is somewhat dramatic and most unusual. Is there anyone who feels they could not be part of that process?" No hands were raised. Awaiting the verdict, Sarah held audience with the press. She recounted that she had a personality called "Ginger", who enjoyed getting drunk and picking up men in bars. She refused to allow access to Ginger, stating that, when Ginger last appeared, she had "gone on a bender and nearly killed the body". Sarah stated that one of her personalities, "Leona", was an "empath", able to experience the emotions of all the alters, empath being a term absent from Webster's American Dictionary, but popularised in the television programme "Star Trek". It also transpired that a number of her personalities were male, although no- one appears to have asked her whether these were also raped. In exchange for a cigarette, she brought out a male personality called Evan. "Oh God", said Evan. "I'm wearing a dress! I hate it when that happens". Evan bemoaned the indignity of having to urinate in a sedentary position. "It's the way the body is built", he/she explained. "I tried it standing once, but I missed the john" (Time Inc. Magazine Company and Compact Almanac, 1990; Washington Post, 1990a; Washington Post, 1990b). The jury found Peterson guilty of second degree sexual assault under a section of the criminal code making it an offence to have sexual intercourse knowingly with a person who suffers from a mental illness which renders that person temporarily or permanently incapable of appraising his or her conduct. This offence carries a maximum sentence of ten years. A juror, discussing the jury's deliberations with a reporter after the trial, explained that it had not been necessary for the jury to decide whether Sarah had a multiple personality disorder, but rather whether or not she was ill. After the bizarre proceedings in court, the jury had been satisfied that she must be mentally ill in some way and that this must have been evident to Peterson. The conviction was reversed on appeal (Saks 1994), because the defendant's expert had not been permitted to examine the victim. Prosecutors decided not to retry the case, as a retrial was deemed too traumatic for the victim. The case is not unique in terms of a "multiple" complaining of rape (Saks, 1994). In a 1992 case, James and Marilyn Dorsey were found guilty of the rape of a "multiple". According to prosecutors, "the Dorseys would trigger the 24-year old's vulnerable, child-like persona and then abuse her. To call the 5-year old, they would talk about alleged molestations by the woman's grandfather" (Atlanta Journal and Constitution, 1992). Further examples of alters testifying may be found at various points in the discussion below. There are no other examples of canine alters in the witness box, but mythical beings and animals are not particularly rare in MPD sufferers. In a civil case in Wisconsin in 1997, Nadean Cool sued her therapist, who had brought out more than 120 personalities, including an angel, a devil and a duck. The therapist had then charged group therapy rates. The matter was settled out of court for $2.4 million (Loftus, 1997). Alter personalities discovered by other therapists have allegedly included lobsters, tigers, chickens and Ninja turtles (Observer, 1998). 3) Age of criminal responsibility Slovenko (1989) has asked whether, if the alter in charge at the time of a crime was a minor whilst the host personality was an adult, the trial should be held in juvenile or adult court. In Florida, in 1979, Juanita Maxwell (a maid at a local hotel) was charged with stabbing to death a 73-year old woman with a pair of scissors in an argument about a ball-point pen (Saks, 1997). She claimed that Wanda, one of the seven personalities that allegedly inhabited her body, was responsible. Wanda was nine years old (Slovenko, 1993). Wanda testified: "Juanita was with me, but she wasn't aware of what was going on" (Detroit News, 1995). Slovenko sets out the questions the case raised: "To what extent is a sub-personality allegedly a minor really like a minor? Is a nine-year-old sub-personality like an ordinary nine-year-old. To what extent does the host personality permeate the sub-personality? Does the sub-personality have 'full control' or 'control' over the host personality?" The defendant was found not guilty by reason of insanity, and sent to Florida State Hospital, where her principal therapy was haloperidol in doses of upto 85 mg. per day (Detroit News, 1995). Released in 1986, she was arrested in 1988 for robbery of two banks, actions which were attributed to Wanda. Her lawyer claimed that she was "psychologically absent at the time of the incidents", whereas the prosecuting attorney noted that there was "one person, one set of fingerprints, one set of teeth, one heart, one liver" (Slovenko, 1989). Maxwell eschewed an insanity defence, as she did not wish to be returned to the state psychiatric hospital. In 1991, she was allowed to plead no contest to the bank robberies and given an unusual sentence of three years in gaol, (which she had already served), and probation for life. She has featured on the talk show circuit, including the Oprah Winfrey programme and the CBS programme "60 minutes" (29th September 1991). A television film is "under development" in Hollywood, where the story is said to be "hot property" (Detroit News, 1995). In a more recent case, a 31 year old teacher arrested on child pornography and sexual assault charges produced three teen alters (New York Times, 1997), so presumably rendering his sexual focus more age appropriate. It is perhaps surprising that more cases involving child alter perpetrators have not been reported, given the frequency (and popularity) of child alters in MPD cases. In 1989, there were said to be ten women on death row with a diagnosis of multiple personality disorder (Slovenko, 1989). It is unclear what would happen to someone facing execution, if a child alter became predominant. Interpretation of "competency to be executed" in many states focuses on an inmate's ability to understand his situation, whilst others also require an ability to assist a lawyer in the appeals process. Saks (1997) has suggested that a predominant child alter might fail these criteria, if he/she was too young to understand the concept of death or to instruct his/her lawyer. 4) Discontinuance and the public interest The tendency to be overwhelmed with the bizarreness of the presentation is evident in early cases from the USA. In a 1979 case in San Bernardino, California, the MPD phenomenon was taken literally, and Esther Minor was found not guilty of forgery (without insanity being an issue), because her alter personality, Raynell Potts, admitted writing the bad cheques concerned (Ashby, 1979). In a further case in Hawaii in 1984, six psychiatrists testified with little or no agreement between them (State v. Rodrigues, 1984; Slovenko, 1989; Perr, 1991; Steinberg et al., 1993; Saks, 1997). The defendant, a 23- year old marine, was charged with three counts of sodomy and one of rape; his victims were all young girls, whom he would lure into secluded areas. The court summarised the testimony as follows: "The defendant had anywhere from one to three personalities - personality A could appreciate the wrongfulness of his acts and conform his behaviour to the requirements of the law, but could not control B; B could understand the wrongfulness of his conduct but could not conform his behaviour to the requirements of the law; and personality C did not care whether what he did was right or wrong, or about the consequences of his conduct." One psychiatrist, theorising that there was one personality, testified that A committed the acts; four doctors, theorising that there were two personalities, testified that B committed the acts; and another psychiatrist testified that C committed the crimes. The judge found that evidence of MPD was such overwhelming proof of insanity that he granted an acquittal, without putting the matter to a jury. His decision was later overturned on appeal, because of his failure to put the matter to a jury (see below). Such defences have not always been successful. In another case (State v. Darnall, 1980; Slovenko, 1993), the defence counsel argued that undeniable evidence of MPD is such overwhelming proof of mental disorder that the trial court was bound to find the defendant not responsible for his actions as a matter of law. Five experts gave evidence. All agreed that the defendant suffered from MPD. The primary personality, Ned, was said to be weak, ineffectual and highly dependant on his father, whose murder was the subject of the case. When Ned was subjected to more emotional stress than he could handle, an aggressive second personality, Nathan, would appear and take charge. One expert also discovered a third, well-balanced personality named Nate. The three defence experts were all of the opinion that, while Ned could appreciate the criminality of his actions, he was unable to conform his conduct to the law because of his disorder. The state's two experts did not think that an alternating personality would necessarily preclude responsibility. The court concluded that this evidence was sufficient to put the matter of responsibility to a jury, and denied a directed verdict. The jury found Darnall guilty of murder. Fitness to plead (competency) and insanity defences In the USA, MPD has been used as an argument that a defendant was unfit to plead in competency hearings. In at least two murder cases, defendants with MPD have been found incompetent to stand trial (Coons, 1991). The very assessment process for competency can be complicated by the MPD diagnosis. Griffith (in Allison 1982) asks which personality should be examined for competency, whether they should all be examined as they appear, and, if so, which one should be used. In State v. Badger (1988), discussed further below, it was contended that the defendant was unfit, because he could not control the switching of his personalities and this might happen in court, with each personality having no memory of what had just happened to the other. The court held that: "This problem, should it occur during trial, can be overcome by having the defendant's attorney explain to him what has occurred just prior to the personality change" (Lewis and Bard, 1991; Steinberg et al., 1993; Saks, 1997). Further cases concerning MPD and competency are cited by Saks (1994 & 1997). Insanity defences on the grounds of multiple personality appear to go back at least until 1977. The earliest successful such defence was in the case of William Milligan, a 23-year old man from Ohio, who was arrested for a series of nine rapes on a university campus (State v. Milligan, 1978; Keyes, 1981). His lawyers decided upon an evaluation by a psychologist because of his inconsistent presentation and demeanour. The psychologist found his IQ to be 68, diagnosed schizophrenia, and stated that he was not competent to stand trial. The judge then ordered an assessment for the court by a local forensic psychiatry unit. The psychiatrists involved diagnosed MPD, and called in Dr. Cornelia Wilbur, the psychiatrist who had explored the 16 personalities of Sybil, the subject of a best-selling book and a television film (Schreiber, 1973). She confirmed the diagnosis, and the court agreed to a three-month period of inpatient evaluation and treatment. The doctors succeeded in "partial fusion" of the personalities involved, sufficient that Mr. Milligan could be deemed competent to stand trial. Evidence was submitted that the rapist was not Milligan, but Adelena, an alternative personality, who was a nineteen year old lesbian. Milligan was said to have ten personalities: two females who craved affection and eight males who hated sex. The principal Milligan personality was said to be unaware of Adelena or of her actions. Milligan waived the right to jury trial. The court-appointed psychiatrists all supported the NGRI plea. The prosecuting attorney decided not to challenge the psychiatric evidence. The judge stated that, lacking any evidence to the contrary, he was obliged to make an NGRI finding. Milligan was admitted to an open psychiatric unit. The judge described the history of Milligan's life, including early alleged childhood sexual abuse (hotly contested by the family), as "mind-boggling", an adjective that some evidently thought might better be applied to the outcome in court, which Thigpen & Cleckley (1984) described as "a gross miscarriage of justice and denigration of psychiatry". Milligan was eventually released from hospital in 1988, with the total 24 personalities finally identified having been "fused". Ohio is taking legal steps to recover part of the $453,000 that his hospital stay is said to have cost, following the success of 'The Minds of Billy Milligan' (Keyes, 1981). A film of the case is said to be planned with the working title 'The Crowded Room'. Subsequent arrest has not been accompanied by an MPD presentation (Columbus Dispatch, 1996). Details of two further successful insanity defences are available, both in murder trials. In another early case from 1980 in Sacramento, California, Paul Miskimen was found not guilty by reason of insanity for the murder of his wife (Sacramento Bee, 1980; Allison, 1982). All the psychiatrists involved in the Miskimen case agreed that the murder was committed by Miskimen's "alter personality" while in a "co- conscious state" and that Paul Miskimen himself had no capacity to stop the killing (Allison, 1982). In the case of Mr. A, who murdered his girl-friend in August 1985 (Perr, 1991), the exact date of the offence was not known as various parts of the dismembered body were found in plastic rubbish bags throughout the county park system over an eight day period. The body was decapitated and the trunk was severed, with the limbs sawn off. Mr. A denied that he had committed the murder, but stated that one of his other personalities, Billy Ray, might have done it. An interviewing psychiatrist found evidence of the appearances of Billy Ray ("a vicious sociopath") in Mr. A's past, dating back to 1968. There had been assaults with a knife and a hammer, and Mr. A had a long history of psychiatric admissions with twenty-one different diagnoses over the years. Mental state examination of Mr. A was unremarkable. The psychiatrist advised the court that all could be explained in terms of multiple personality disorder, and that Mr. A. did not meet the standards required for criminal responsibility. He explained: "Because of the nature of this condition, the host personality is not able to fully know right from wrong, or even to know the nature and quality of the act". The court found Mr. A "not guilty by reason of insanity". Four years later, his therapist at the admitting hospital reported that seven distinct personalities had now emerged. The frequency of insanity defences on the basis of MPD in the USA is not known. Coons (1991) found nineteen US cases between 1977 and 1991 where MPD was used as the basis of an insanity defence in homicide cases. At least two were found not guilty by reason of insanity, two incompetent to stand trial and one guilty, but mentally ill. In at least one case, the diagnosis had been made before the murder took place. In those cases where the defence was rejected, it is not known upon what basis the juries had arrived at their conclusions; whether they did not believe in MPD, did not believe the defendant, or did not agree that MPD warranted a finding of NGRI. Coons comments that a follow-up of the cases to see whether the MPD behaviour continued after the conviction would be pertinent. Owens (1997) lists forty-two cases, in which MPD was raised as a defence. Steadman et al. (1993) conclude from an eight state US survey covering the late 70s to the mid-eighties that MPD is used infrequently in insanity defences. The survey found that only 15 of 7,689 insanity defence cases for which diagnostic information was available involved defendants with a diagnosis of MPD. However, use of the defence is not equally distributed, seven of these fifteen MPD cases coming from a single state (Appelbaum and Greer, 1994), and extrapolation from the survey to all 52 states would be unreliable. In the decade following the survey, MPD has continued to be used as the basis of insanity defences. The overall number of MPD cases diagnosed in North America has increased into the thousands, and it becomes increasingly likely that pre-diagnosed MPD sufferers will come into contact with the legal system, the pre-existence of the diagnosis being likely to strengthen the case for defences based upon its presence. Lewis and Bard (1991) have summarised the major defences based on multiple personality disorder into four, the second relating to competency and the other three to insanity: "1) The defendant has no control over the actions of his or her secondary personalities and can therefore not be held responsible for them. 2) The defendant does not remember the acts of secondary personalities and therefore cannot participate in his or her own defence. By virtue of suffering from MPD, it is impossible for the defendant to conform his or her behaviours to the law or to know right from wrong. Like a sleep-walker, the defendant was unconscious of alternates behaviours and hence cannot be held accountable for them." From the judicial decisions in a series of cases in different states, it is possible to discern signs of a common approach to some of these issues beginning to take form. The approach, however, is flawed. Seven such judgements are examined below:- i) The case of Robin Grimsley in Ohio in 1982 (State v. Grimsley, 1982; Perr, 1991; Lewis & Bard, 1991; Saks, 1997) involved the appeal of a woman who had pleaded "no contest" to a charge of drunken driving. She had previously been diagnosed as suffering from MPD, for which she was receiving therapy. She claimed that, at the time of the offence, distress over the report of a lump in her breast had lead her to dissociate into an "alter", Jennifer, who was impulsive, angry and alcoholic. She denied any memory of, or control over, Jennifer's actions, and so had "acted unconsciously, or involuntarily without volition and therefore had committed no crime". The court concluded that the evidence did not establish that Jennifer was either unconscious or acting involuntarily: "There was only one person driving the car and only one person accused of drunken driving. It is unmaterial whether she was in one state of consciousness or another, so long as in the personality then controlling her behaviour, she was conscious and her actions were a product of her own volition. The evidence failed to demonstrate that Jennifer was unconscious or otherwise acting involuntarily". The court thereby made the point that, as long as the "alter" who was "in control" at the time was aware of what she was doing and able to exercise volition, then the (whole) person would be held responsible. A second claim made in the appeal was that Robin could not give evidence because she was largely amnesic for Jennifer's actions. The court concluded: "If we were to allow the bare existence of a defendant's multiple personality to excuse criminal behaviour, we would also relieve from responsibility for their criminal acts all defendants whose memories are blocked". The court therefore confirmed that amnesia for an offence did not in itself constitute a reason for lack of criminal responsibility, or imply a failure to form an intent. ii) A Georgia court in 1983 tended in the same direction when faced with Phyllis Kirkland, a woman charged with two bank robberies, who asserted that these had been committed by a different personality, "Bad Sharon" (Kirkland v. State, 1983; Perr, 1991; Lewis & Bard, 1991; Saks, 1997). Dressed in each case in a wig, a jogging suit and sunglasses, she had threatened bank employees with a gun and mace spray and had escaped in a black Cadillac with darkened windows. The Court reached the following conclusion: "In the facts of this case, the purported fugal personality, "Bad Sharon", is a well-developed, rational and conscious personality, so for legal purposes we will not distinguish them". And: "The law adjudges criminal responsibility according to a person's state of mind at the time of the act; we will not begin to parcel criminal accountability out among the various inhabitants of the mind". A verdict was reached of "guilty, but mentally ill". What was found to be determining in this case was that the alter who committed the robberies did so with "rational, purposeful criminal intent and with knowledge that it was wrong". In other words, the court considered the state of mind of the alter at the time of the crime. The lower court's finding was upheld on appeal. iii) The final judgement in Rodrigues (State v. Rodrigues, 1984) leaves unclear the question as to whose mental state should be focused on. The court stated: "Since each personality may or may not be criminally responsible for its acts, each one must be examined under the American Law Institute (ALI)-Model Penal Code (MPC) competency test". Here, it is not clear whether the "multiple" meets the insanity test if any "alter" is insane, or only when the "alter" who committed the crime is insane. The latter is suggested later in the judgement: " Responsibility is a question for the jury where, as here, there are diverse opinions as to which personality performed the act and whether that personality was sane or not". Saks (1997) finds the suggestion that all the personalities should be examined as regards criminal responsibility wasteful of resources. In her view, it would be better to establish which alter was in control at the time of the offence and then go on to examine that alter. iv) In a case in New Jersey in 1988, already referred to above, (State v. Badger, 1988; Perr, 1991; Lewis & Bard, 1991), the court considered "whether a person who suffers a multiple personality disorder is mentally competent to stand trial for a crime committed by a personality other than the dominant one". Christopher Badger was said to have eight different personalities and had been diagnosed as suffering from MPD at the age of 17. He alleged that the attempted burglary in question had been committed by an alter, Philip, and that Christopher had no memory of any of the events of that evening. A psychiatrist reported that both Christopher and Philip knew right from wrong, but that only Philip could relate the facts and co-operate in his defence; and Philip could change back into Christopher at any time. The court saw this as analogous to a defence of amnesia and stated: "New Jersey has flatly refused to allow amnesia concerning a crime to be a bar to prosecution". v) In a case from Massachusetts in 1993 (Commonwealth v. Roman, 1993; Appelbaum & Greer, 1994; Saks, 1997), Norma Roman was charged with possession of heroin with intent to supply. A large quantity of heroin, some cocaine and a large sum in cash had been found in her flat. Ms. Roman claimed to have MPD. She gave evidence that, whenever she found drugs in the flat, she threw them out. Two of Ms. Roman's seven alters also gave evidence. "Vicky" admitted that she sold drugs, although she knew it was illegal. "Alice Meijas" gave evidence that she knew about Vicky's activities, but was unable to control them. Norma pleaded not guilty by reason of insanity on the grounds that, in Massachusetts, an insanity finding may occur when the defendant lacks "substantial capacity to appreciate the wrongfulness of his behaviour or to conform his behaviour to the requirements of the law." In instructing the jury, the trial judge stated that they "must focus on the particular mental statein which you find the defendant was operating at the time of the criminal conduct". This implied that, if the personality in control at the time of the offence did not qualify for an insanity verdict, then the defendant must be found guilty. Norma appealed against her subsequent conviction on the grounds that the judge should not have focused on the personality in control at the time (Vicky), but rather on the "core" personality (Norma), and whether or not Norma lacked the capacity to control Vicky and so conform her conduct to the requirements of the law. The appeal court concluded: "Our law requires jurors to determine criminal responsibility of the person at the time of the commission of the crime. The judge so instructed the jury. There was no error". vi) In State v. Wheaton (1993), which is discussed at length by Behnke (1997a), defendant Dea Wheaton contended that an alter personality named Cassie was "in executive control of the physical body" at the time of the offence. The Supreme Court of Washington was asked to define the standard by which to determine whether someone with MPD met the legal definition of insanity. A psychiatrist appointed by the trial court had outlined two approaches; the "global" approach, which would "result in a finding of insanity whenever the host personality is not in executive control or co-conscious at the time of the offense"; and the "specific alter" approach, which depended on whether the "alter that was in executive control at the time of the offense" were legally sane. The court did not find the specific alter approach helpful, as there was no indication as to why the alter in charge at the time should be found responsible. In considering the global approach, the court looked to the principle that "one who is unconscious at the time of the act is not responsible for his or her criminal acts", but did not find this to resolve the issue: "It is not enough to say that Dea Wheaton was unconscious at the time of the offense. That would matter if the focus should be on the personality Dea Wheaton. If the focus here should be on the alter in executive control, as the trial court concluded, the question would be whether Cassie was conscious at the time of the offense.The fact that Dea Wheaton was not conscious does not help resolve the underlying question, i.e. is it proper to focus on the alter personality?" vii) New ground appears to have been broken with the case of Denny- Shaffer (US v. Denny-Shaffer, 1993; Appelbaum & Greer, 1994; Saks, 1997). Ms. Denny-Shaffer, a mid-wife in New Mexico, was accused of kidnapping a baby from a hospital nursery. She had gone to a neighbouring hospital, posing as a medical student on a paediatrics rotation. She selected an infant, and left with it under her arm. During the next three weeks, she drove to Texas, where she tried to convince an old boy-friend that he was the father of the child. She had also visited her parents in Minnesota and told them the same story. Later, it was said that the offence had been conducted by two alters, Rina (an irresponsible adolescent) and Bridget (a "Mother Superior" personality). Gidget, the host personality, was "not present" at the time of the abduction. At trial, the issue arose as to whether the defendant was able, in the words of the statute, to "appreciate the nature and quality or the wrongfulness of his acts". One expert in his evidence set out the choice before the court in its interpretation of the statute, as to whether the test should be applied to the host personality or the alter in control. There were two possible ways of assessing the defendant's responsibility:- "(1) that in the light of the presence of a host personality and several alter personalities, if the statute means that all alters, or at least the host personality, must be fully aware of the nature, quality, and wrongfulness of an act, then Denny-Shaffer was not responsible at the time of the abduction; and (2) on the other hand, if an MPD victim is viewed as a single individual with varying personality components, and not divided as separate people, the issue changes; in such a case the question would be whether the personality in control at the time of the offence was unable to understand the nature, quality and wrongfulness of her acts. If this is the proper interpretation of the statute, then the defendant did suffer from a significant mental illness, but it was not such as to render her unable to understand the nature, quality and wrongfulness of her acts". The original trial judge, adopting the second argument, (similar to the rationale in Commonwealth v. Roman), had refused to allow consideration of the insanity defence after hearing a prosecution expert state that the two alters in control at the time of the offence were aware of the wrongfulness of their acts, and a defence witness say that she could not be sure whether the controlling alters understood the wrongfulness of their acts. On appeal, the trial court's approach was over-ruled. The appeal court concluded that the host personality should be understood to be the defendant, and that "it is the host or dominant personality, which must be the focus of possible criminal responsibility". Denny-Shaffer ought to be permitted to put her defence to the jury: "We hold that, where the evidence would permit a jury to find that a defendant suffers from MPD and that the host personality was unaware of the criminal conduct at issue and did not participate in or plan that conduct, the jury may also find that the "defendant" satisfied (the statutory) requirements and thus return a verdict of not guilty by reason of insanity." The striking feature of these cases is that both defence and prosecution experts appear to agree about the presence of multiple personality and the committing of crimes when an "alter" is in control. Once this is taken as given, the court is obliged to try and make sense of the situation in terms of existing competency and insanity laws. The tendency of the courts in these cases, presumably in an attempt to preserve the integrity of the accused, appears paradoxically to be to deny that a single person is on trial and to treat individuals with MPD as though they are several different people, each of whom may be held responsible for his or her own behaviour. The courts appear to have been trapped into a logical inconsistency. If it is the mental state of the so-called alter personalities in control at the time of the offence that is considered in relation to insanity pleas, then the integrity of the "host" personality is lost. If the "host" personality and its state at the time of the offence is taken as predominant, then the integrity of the individual (and common sense) are preserved, but responsibility is parcelled off to personality fragments with no independent existence. (The judgement in Kirkland v. State appears self-contradictory in this respect). No solution to this conundrum is apparent, unless the whole basis of the "multiple personality" diagnosis is rejected. Saks (1992, 1994, 1997) argues at great length for a simpler position, which goes considerably beyond what any court has yet been prepared to accept. This is that the presence of multiple personality disorder per se should be sufficient for a finding of not guilty by reason of insanity. The only exception would be where it can be shown that all the alters participated actively in the offence. This accounts for the title of her 1997 book ("Jekyll on Trial", written "with Stephen H. Behnke"), in which she contends that Jekyll would have been guilty of the offences committed by Hyde, because he was aware of what had taken place and nevertheless again took the transforming potion. Radden (1996) indicates that, since multiples do not fit into the current insanity and involuntariness defences as currently formulated, they must be found responsible in criminal law. Saks (1997) disagrees, arguing that the law is "not lifeless and unchanging" and that the law should be reformulated to allow MPD cases to be found non-responsible. In the interim, in her view, multiples should be fitted into current formulations of the insanity defence wherever possible. Most recently, Behnke (1997a & 1997b) has set out his differences with Saks. He argues that the defendant is only one person and that the courts should treat the different personalities as exotic elements of the mental state, consideration of which at the time of the offence may be relevant to the insanity issue. This advice appears sensible, as far as it goes. However, Behnke appears to accept the idea of "severe dissociation" into different personalities. If this is adhered to, the courts must still struggle with the issues of involuntariness and amnesia, complicated by difficulty in determining the presence of an alter personality, the total or partial absence of the host personality, and the difficulty in excluding malingering. 6) Treatability and dangerousness MPD is said to be "eminently treatable" (Saks, 1997) and, according to Ross (1997), "there is no psychiatric disorder of comparable severity that carries such a good prognosis". The treatment is based on psychotherapy and can be lengthy (Ross, 1997). Ross claims that most "committed, motivated" (and, presumably, non-forensic) patients can be treated to stable integration within an insurance policy providing for 100 days of inpatient treatment and 500 hours of individual outpatient psychotherapy, this meaning about $100,000. This is predicated upon the existence of suitable treatment facilities and personnel. The problem, in terms of the compulsory inpatient treatment of offenders, is how it can be judged when a person is "cured" of his or her affliction and therefore safe for release. It is said to be characteristic of alters that they can lie dormant for years, before suddenly reappearing (Piper, 1994). Even if an offending alter has not appeared for a number of years, how can there be any indication as to whether he will or won't reappear in the future? The standard "treatment" for MPD is "fusion", but, as French & Shechmeister (1983) state: "Adequately objective criteria for fusion have yet to be agreed upon.Retrospective proof of adequate fusion may be difficult to establish." And, if the person is a collection of personalities, then the person would remain potentially dangerous, because their capacity to control undesirable conduct would be limited (Halleck, 1990). A collective would be unlikely to be responsive to the sanctions that control behaviour in most of the population and, as such, society would be obliged to take control over its actions. Although the usefulness of MPD as mitigation has been described (Abrams, 1983), the dangerousness issue might limit its role in this respect, as in the U.S., dangerousness can be adjudged to be an aggravating factor in death penalty decisions (Saks, 1997). Punishment, personality and "personhood" For courts to accept the existence of alters literally, or to consider evidence as to the mental state of different alters, may facilitate their dealing with competency and insanity issues in the "multiple" presentation; but such an approach is fundamentally flawed when it comes to dealing with issues of sentencing. There is, in the end, only one "body". Saks (1992, 1994, 1997), currently Professor of Law, Psychiatry and Behavioural Sciences at the University of Southern California, has argued at length that it is unjust to imprison innocent alters for the misdeeds of a different alter. Would we wish to imprison both Siamese twins for the crimes of one of them?, she asks. If the body is imprisoned, how do we know that the guilty alter will not simply choose to be absent for the length of the sentence, leaving innocent alters to suffer the punishment? She contends that the imprisonment of multiples is unjust, whether alters are considered as individual people, "personlike centres of consciousness" or "nonpersonlike parts of one deeply divided person". Her views appear to have achieved some degree of acceptance in the judgement in the Denny-Shaffer appeal, where the court alluded to the perceived unfairness of convicting a host personality for behaviour beyond his or her control. However, her positions remain on the extreme of the spectrum of approaches to MPD (Appelbaum & Greer, 1994). Towards the other end lies the view reported by Halleck (1990) that it can be an important part of the treatment of the disorder to hold the person with multiple personality disorder responsible for the behaviour of their alters in that it will encourage the exercise of control by the host personality. There is some superficial validity to the idea that it would be unjust to hold the whole individual blameworthy, if seen as a collection of relatively autonomous personalities. A closer examination of the issue suggests that an individual with a set of autonomous alters is no longer a morally or legally accountable person recognisable by society, but rather a collection of partial persons with no collective capacity for responsibility. Halleck (1990) questions whether such a "fragmented" person would be able to exercise the fundamental ability to choose. If there are different autonomous personalities within the individual, then how can that individual legally choose to enter contracts, make a will, undergo voluntary treatment in a psychiatric hospital or have voluntary sexual relationships? Can informed consent truly be obtained from multiples for surgical procedures (Greenberg & Attia, 1993)? Indeed, is it possible to obtain informed consent for psychotherapeutic treatment of an MPD patient (Halleck, 1990)? Slovenko (1989) details a number of therapists, who obtain written consent from all known personalities, including the "caretakers" of any child alters, before commencing therapy. Griffith (in Allison 1982) asks what happens in the case of a "multiple" choosing to waiver constitutional rights: would each of the "personalities" have to waive their rights, or would one be sufficient? Some judges are requiring that each personality testifying at a trial be sworn in and given the oath (Slovenko, 1989). Should therefore a search or arrest warrant be issued for each personality? Should each personality be read their rights? Is there a Tarasoff duty if one alter, in therapy, threatens to kill another, who is not co-conscious? Such arguments come down to what is understood by "personhood" (the term used in such discussions for "being a person"), personality, individuality and their relationship to the "host body" (Gillett, 1986). If MPD is seen as the fracture of the personality into different persons in early childhood secondary to trauma, with each personality developing in parallel and to more or less the same degree, with partial or total ignorance of the others, then the argument that alters should be seen as equal in terms of the court is perhaps understandable. Not all proponents of the MPD cause would follow this line. Ross (1997) is firm that alters are "dissociated components of a single personality". He finds (1997) the defence of not guilty by reason of insanity inappropriate in MPD. He contends that mental state should be irrelevant to a determination of guilt or to sentencing, arguing that psychiatric evidence should only be considered in deciding where the sentence should be spent, in hospital or in prison. Saks (1997) does not find the idea of "healing" a multiple for the purpose of punishing him unusual, given that the Supreme Court of the United States has upheld the constitutionality of "curing" a death row inmate solely for the purpose of killing him (Ford v. Wainwright, 1986). Her objection is in equating the integrated person with the guilty one: "The integrated person would be as much a different person from the guilty alter as the guilty alter is from the innocent alters. Thus, the culpable person would no longer exist, and the new person would not be culpable". Many authorities would see these forms of argument as sophistry or casuistry. However created, the multiple personality situation is one of evasion and self-deception (Beahrs, 1994). For clinicians and others to sanction MPD as an illness is simply to sanction the individual's avoidance of their own personal responsibilities and to allow them to seek refuge in a socially-sanctioned sick role (Halleck, 1988; Fahy, 1988; McHugh, 1995). This appears to be the crux of the matter. Although the arguments about MPD in the US courts are far from resolved, many may sympathise with Bloom, (quoted by Slovenko, 1989), who writes: "Having worked with patients for 40 years now, I see splitting and dissociation, not only as defences, but as means to escape moral responsibility for ourselves and our actions.The murderers and the rapists can hide behind their numerous personalities to get away with the crime. And society is reinforcing this sociopathy more and moreEach person should be held responsible for his own personality. If it is split, it is his fault. If he errs when he is split, he should be held accountable". Relevance to UK practice It might be argued that the MPD phenomenon is not one to exercise forensic psychiatrists on this side of the Atlantic, where there are no "experts" willing to promote the MPD cause in court, no specialised dissociation clinics and no specialist journal devoted to the cause. What Piper (1997) refers to as the "fringe triad of recovered memory therapy, MPD and Satanic ritual abuse therapy" is foreign to U.K. psychiatry, and the phenomenon of MPD remains largely restricted to North America (Fahy, 1988; Merskey, 1992; Piper, 1994; Spanos, 1996). Although some argue that the disorder is not found elsewhere because it is not looked for (e.g. Bliss, 1984b; Kluft, 1991; Ross 1997), Spanos (1996) explains its culture-bound nature in socio-cultural terms. He considers that it has spread so far in the U.S.A., because it fulfils a social, political and cultural function, suiting desires to evade personal responsibility and to medicalise personal dissatisfaction and distress, whilst fitting the agendas of groups as diverse as the therapy professions, the political right, conservative Christian evangelists, the child abuse lobby and believers in alien abduction. No such context exists in the U.K. But whether it be a cult, an industry or a legitimate field of medical science, the MPD movement is now large and established in North America, and MPD remains defined as a mental disorder in both ICD-10 (World Health Organisation, 1992) and in DSM-IV (American Psychiatric Association, 1994), where it has been dignified with the less controversial appellation "Dissociative Identity Disorder". The weight of material written about MPD (see Ross (1997) for a list of recent books) tends to lend the idea a certain legitimacy in the "therapy" world. Ideas have a tendency eventually to permeate cultural boundaries, with or without the proslatysing activities of proponents, such as Ross, who lectured and led workshops with 150 therapists on a 1997 UK tour, which achieved considerable media and television coverage (Independent on Sunday, 1997). We contend that a firm view should be adopted by British forensic psychiatrists. In brief, there should be no place in the practice of forensic psychiatry for 'psychological alchemy' or 'siances in the court-room'. The aim should be to validate Aldridge- Morris' rather optimistic claim (1989) that: "In the U.K., we react to any suggestion that there are two or more personalities by immediately saying that there are two or more aspects to one personality, and asserting that the individual must take responsibility for both of these aspects. It works." (Word count = 8479) REFERENCES Abrams, S. (1983) 'The multiple personality: a legal defence'. American Journal of Clinical Hypnosis 25(4): 225-31. Aldridge-Morris, R. (1989) Multiple personality: an exercise in deception. London: Lawrence Erlbaum. Allison, R.B. (1982) 'The multiple personality defendant in court'. American Journal of Forensic Psychiatry 3: 181-91. American Psychiatric Association. (1980) Diagnostic and statistical manual of mental disorders, 3rd edition (DSM-III). Washington, D.C.: American Psychiatric Association. American Psychiatric Association. (1994) Diagnostic and statistical manual of mental disorders, 4th edition (DSM-IV). Washington, D.C.: American Psychiatric Association. Appelbaum, P.S. & Greer, A. (1994) 'Who's on trial? Multiple personalities and the insanity defence'. Hospital and Community Psychiatry 45: 965-6. Ashby, A. (1979) 'Esther minor: multiple personalities in court'. Forum 6: 3-30. Atlanta Journal and Constitution (1992) 'Hall Jury Finds Librarian Guilty in Rape Trial. Woman Who Had 17 Personalities Couldn't Have Consented, Jury Says'. 20th May 1992. Beahrs, J.O. (1994) 'Dissociative identity disorder: adaptive deception of self and others'. Bulletin of the American Academy of Psychiatry and the Law 22(2): 223-237. Behnke, S.H. (1997a) 'Confusion in the courtroom. How judges have assessed the criminal responsibility of individuals with multiple personality disorder'. International Journal of Law and Psychiatry, 20: 293-310. Behnke, S.H. (1997b) 'Assessing the criminal responsibility of individuals with multiple personality disorder: legal cases, legal theory'. Journal of the American Academy of Psychiatry and the Law, 25: 391-399. Bliss, E.L. (1980) 'Multiple personalities: a report of 14 cases with implications for schizophrenia and hysteria'. Archives of General Psychiatry 37: 1388-97. Bliss, E.L. (1984a) 'A symptom profile of patients with multiple personalities, including MMPI results'. Journal of Nervous and Mental Disease 172(4): 197-202. Bliss, E.L. (1984b) 'Spontaneous self-hypnosis in multiple personality disorder'. Psychiatric Clinics of North America 7(1): 135-48. Bliss, E.L. & Jeppsen, E.A. (1985) 'Prevalence of multiple personality disorder among inpatients and outpatients'. American Journal of Psychiatry 142(2): 250-1. Boor, M. (1992) 'The multiple personality epidemic'. Journal of Nervous and Mental Disease 170: 302-4. Casey, J.F. (1991) The Flock. Alfred A. Knopf: New York. (Published in U.K. in 1993 by Abacus) Columbus Dispatch (1996) 'Billy Milligan held in California jail', by A. Johnson. 25th June 1996. Coons, P.M. (1991) 'Iatrogenesis and malingering of multiple personality disorder in the forensic evaluation of homicide defendants'. Psychiatric Clinics of North America 14(3): 757-68. Coons, P.M., Bowman, E.S. & Milstein, V. (1988) 'Multiple personality disorder: a clinical investigation of 50 cases'. Journal of Nervous and Mental Disease 176(9): 519-27. Detroit News (1995) 'Life's still a struggle for Juanita's seven identities', by C. Pittman. 6th October 1995. Dinwiddie, S.H., North, C.S. & Yutzy, S.H. (1993) 'Multiple personality disorder: scientific and medicolegal issues'. Bulletin of the American Academy of Psychiatry and the Law 21(1): 69-79. Fahy, T. (1988) 'The diagnosis of multiple personality disorder. A critical review'. British Journal of Psychiatry 153: 597-606. Freeland, A., Manchanda, R., Chiu, S., Sharma, V. & Merskey, H. (1993) 'Four cases of supposed personality disorder: evidence of unjustified diagnoses'. Canadian Journal of Psychiatry 38: 245-7. French, A.P. & Shechmeister, J.D. (1983) 'The multiple personality syndrome and criminal defence'. Bulletin of the American Academy of Psychiatry and the Law 11(1): 17-25. Gillett, G.R. (1986) 'Multiple personality and the concept of a person'. New Ideas in Psychology 4(2): 173-84. Greenberg, W.M. & Attia, S. (1993) 'Multiple personality disorder and informed consent'. American Journal of Psychiatry 150(7): 1126-7. Hardy, D.W., Daghestani, A.N. & Egan, W.H. (1988) Multiple personality disorder: failure to diagnose and the potential for malpractice liability. Psychiatric Annals, 18: 543-548. Halleck, S.L. (1988) 'Which patients are responsible for their illnesses?' American Journal of Psychotherapy 42(3): 338-353. Halleck, S.L. (1990) 'Dissociative phenomena and the question of responsibility'. International Journal of Clinical and Experimental Hypnosis 38: 298-314. Hawksworth, H. & Schwarz, T. (1977) The Five of Me. Chicago: Regnery. Independent on Sunday (1997) 'American therapist that could blow your minds', by M. Jenkins. 9th February 1997. Keyes, D. (1981) The minds of Billy Milligan. New York: Random House. (Published in the U.K. in 1995 by Penguin). Kluft, R.P. (1991) 'Clinical presentations of multiple personality disorder'. Psychiatric Clinics of North America 14(3): 605-29. Loftus, E.F. (1997) Creating false memories. Scientific American, September: 50-55. Lewis, D.O. & Bard, J.S. (1991) 'Multiple personality and forensic issues'. Psychiatric Clinics of North America 14(3): 741-56. Los Angeles Times (1990) 'Rape charge hinges on split personalities: the victim displays three different personalities during testimony'. 17th August 1990. McHugh, P.R. (1995) 'Resolved. Multiple personality disorder is an individually and socially created artefact'. Journal of the American Academy of Child and Adolescent Psychiatry 34(7): 957-60. Merskey, H. (1992) 'The manufacture of personalities. The production of multiple personality disorder'. British Journal of Psychiatry 160: 327-40. New York Times (1994) 'Multiple personality cases perplex legal system', by J. Scott. 9th May 1994: A1 . New York Times (1997) 'Teacher is arrested in internet child pornography case', by R. Hawley. 1st April 1997: B3. Observer (1998) 'Twenty-five years ago a psychiatrist stunned the world with the story of Sybil', by E. Showater. 14th June 1998. Orne, M.T., Dinges, D.F. & Orne, E.C. (1984) 'On the differential diagnosis of multiple personality in the forensic context'. International Journal of Clinical and Experimental Hypnosis 32(2): 118-69. Perr, I.R. (1991) 'Crime and multiple personality disorder: a case history and discussion'. Bulletin of the American Academy of Psychiatry and the Law 19(2): 203-14. Piper, A. (1994) 'Multiple personality disorder'. British Journal of Psychiatry 164: 600-12. Piper, A. (1997) Hoax and Reality. The Bizarre World of Multiple Personality Disorder. Northvale, New Jersey: Jason Aronson Inc. Putnam, F.W., Guroff, J.J., Silberman, E.K., Barban, L. & Post, R.M. (1986) 'The clinical phenomenology of multiple personality disorder: review of 100 recent cases'. Journal of Clinical Psychiatry 47(6): 285-93. Radden, J. (1996) Divided minds and successive selves: ethical issues in disorders of identity and personality. Cambridge, Massachusetts: MIT Press. Ross, C.A. (1997) Dissociative identity disorder: diagnosis, clinical features and treatment of multiple personality disorder. John Wiley: New York. Ross, C.A., Norton, G.R. & Wozney, K. (1989) 'Multiple personality disorder: an analysis of 236 cases'. Canadian Journal of Psychiatry 34(5): 413-8. Ross, C.A., Miller, S.D., Reagor, P., Bjornson, L., Fraser, G.A. & Anderson, G. (1990) 'Structured interview data on 102 cases of multiple personality disorder from four centres'. American Journal of Psychiatry 147(5): 596-601. Sacramento Bee (1980) 'Planner found legally insane in wife's strangulation slaying', by W. Wilson. 18th April 1980: 1 & 24. Saks, E.R. (1992) 'Multiple Personality Disorder and criminal responsibility'. U.C. Davis Law Review 25: 383-461. Saks, E.R. (1994) 'Does multiple personality exist? The beliefs, the data and the law'. International Journal of Law and Psychiatry 17(1): 43-78. Saks, E.R. (1997) Jekyll on trial. Multiple personality disorder and criminal law. New York University Press: New York and London. Schreiber, F.R. (1973) Sybil. Chicago: Regnery. (Published in the U.K. in 1974 by Penguin). Serban, G. (1992) 'Multiple personality: an issue for forensic psychiatry'. American Journal of Psychotherapy 46(2): 269-80. Slovenko, R. (1989) 'The multiple personality: a challenge to legal concepts'. Journal of Psychiatry and Law 17: 681-715. Slovenko, R. (1993) 'The multiple personality and the criminal law'. Medicine and Law 12: 329-40. Spanos, N.P. (1996) Multiple identities and false memories: a sociocognitive perspective. American Psychological Association: Washington D.C. Steadman, H.J., McGreevy, M.A., & Morrisey, J.P. (1993) Before and after Hinckley: evaluating insanity defence reform. New York, Guilford. Steinberg, M., Bancroft, J. & Buchanan, J. (1993) 'Multiple personality disorder in criminal law'. Bulletin of the American Academy of Psychiatry and the Law 21(3): 345-56. The Troops for Truddi Chase (1987) When rabbit howls. Dutton: New York Thigpen, C.H. & Cleckley, H.M. (1957) The three faces of Eve. New York: McGraw-Hill. Thigpen, C.H. & Cleckley, H.M. (1984) 'On the incidence of multiple personality disorder: a brief communication'. International Journal of Clinical and Experimental Hypnosis: 32: 63-6. Time Inc. Magazine Company and Compact Almanac. (1990) 'The 21 faces of Sarah', by J. Smolowe. Law; 87. Washington Post (1990a) 'The many women on the witness stand: multiple personalities give accounts in rape trial', by C. Gorney. 8th November 1990. Washington Post (1990b) 'Sarah and the many voices inside: Wisconsin woman tells the story of her multiple selves', by C. Gorney. 10th November 1990. World Health Organisation (1992) The ICD-10 classification of mental and behavioural disorders. Geneva: World Health Organisation. U.S. LAW REPORTS Commonwealth v. Roman, 606 N.E. 2d 1333 (Mass. 1993) Ford v. Wainwright, 477 U.S. 399 (1986) Kirkland v. State, 304 S.E.2d 561 (Ga. App. Ct. 1983) State v. Badger, 551 A.2d 207 (N.J. Super. Ct. Law Div.1988) State v. Darnall, 161, 614 P. 2d 120 (Or. Ct. App. 1980) State v. Grimsley, 444 N.E.2d 1071 (Ohio Ct. App 1982) State v. Milligan, 77 CR 11 2908 (Franklin County, Ohio 1978) State v. Rodrigues, 679 P. 2d 615 (Hawai 1984); and 469 US 1078 (1984) State v. Wheaton, 850 P. 2d 507 (Wash. 1993) US v. Denny-Shaffer, 2 F.3d 999 (10th Cir 1993) You may also be interested in this article from the Crime Library: <a href="http://www.crimelibrary.com/criminal_mind/psychology/multiples/10.html">Multiple Personality, Crime & Defense</a> <center><a href="books.html"><img src="/images/books.gif" height="105" width="238" border="0" alt="Astraea's Bookstore... a full line of books on multiplicity & beyond"></a></center> <center>[ <a href="/returnform/mailform.html">Email</a> | <a href="http://guestbooks.pathfinder.gr/sign/astraeasweb/"> Guestbook</a> | <a href="http://www.astraeasweb.net/plural/faq.html">FAQ</a> | <a href="http://www.astraeasweb.net">Home</a> | <a href="http://www.astraeasweb.net/plural">Multiplicity</a> | <a href="http://www.astraeasweb.net/religion">Religion</a> | <a href="http://www.astraeasweb.net/politics">Politics</a> | <a href="http://www.astraeasweb.net/politics/badpsych.html">Anti-Psych</a> | <a href="http://www.astraeasweb.net/politics/fmindex.html">Anti-FMSF</a> | <a href="http://www.astraeasweb.net/silly.html">Silly</a> ] <a href="javascript:history.back();">Back from whence you came</a> </td></tr></table></center> </body></html>