Between Belief and Delusion: Cult Members and the Insanity Plea
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REGULAR ARTICLE Between Belief and Delusion: Cult Members and the Insanity Plea Brian Holoyda, MD, MPH, and William Newman, MD Cults are charismatic groups defined by members’ adherence to a set of beliefs and teachings that differ from those of mainstream religions. Cult beliefs may appear unusual or bizarre to those outside of the organization, which can make it difficult for an outsider to know whether a belief is cult-related or delusional. In accordance with these beliefs, or at the behest of a charismatic leader, some cult members may participate in violent crimes such as murder and later attempt to plead not guilty by reason of insanity (NGRI). It is therefore necessary for forensic experts who evaluate cult members to understand how the court has responded to such individuals and their beliefs when they mount a defense of NGRI for murder. Based on a review of extant appellate court case law, cult member defendants have not yet successfully pleaded NGRI on the basis of cult involvement, despite receiving a broad array of psychiatric diagnoses that could qualify for such a defense. With the reintroduction of cult involvement in the DSM-5 criteria for other specified dissociative disorder, however, there may be a resurgence of dissociative-type diagnoses in future cult-related cases, both criminal and civil. J Am Acad Psychiatry Law 44:53–62, 2016 Cults are generally considered to be new charismatic organization. Because of this perception, it can be groups that espouse religious doctrine that differs difficult for an outsider to know whether a belief is from mainstream beliefs. Common characteristics of grounded in the teachings of a cult or if it is, in fact, such groups are members’ adherence to a consensual delusional. In their article on shared psychotic disor- belief system, the maintenance of a high degree of der and criminal responsibility, Joshi et al.4 stated social cohesiveness, strong behavioral mores that in- that some cults may resemble a case of “mass” shared fluence member behavior, and the recognition of psychotic disorder (a diagnosis in DSM-IV-TR5 that 1 members or group leaders as charismatic or divine. was eliminated in DSM-56), raising the question of Galanter describes a cult as a charismatic group that where cult belief ends and delusion begins. The au- “adds the issue of religious deviancy and rejection of thors posited numerous questions about cults and participation in the majority culture” (Ref. 2, p their beliefs, including when such beliefs should be 1539). In history and in the popular imagination, considered part of a delusional disorder rather than from the Peoples Temple atrocity in Jonestown, 3 cult doctrine and whether cult members may in some Guyana, to the ultraviolent Kevin Bacon show The cases be said to share a psychotic disorder. Newman7 Following, some cults have developed a mysterious expanded on this issue, suggesting that a cult can and troubling reputation in society. catalyze the formation of shared psychotic disorder A defining characteristic of many cults is that “because it involves a dominant individual who dic- members adhere to a set of beliefs and teachings, tates the beliefs, actions, and behavior of several sub- whether written or espoused by leaders, that may servients” (Ref. 7, p 373). appear unusual or even bizarre to those outside of the These questions are particularly germane when evaluating a cult member for a plea of not guilty by Dr. Holoyda is a General Psychiatry Resident in the Adult Psychiatry Residency Program, Department of Psychiatry and Behavioral Sci- reason of insanity (NGRI). Some cult members may ences, University of California, Davis School of Medicine, Sacra- participate in violent crimes, such as murder, in ac- mento, CA. Dr. Newman is Associate Professor of Psychiatry, Depart- ment of Psychiatry, St. Louis University School of Medicine, St. Louis, cordance with a cult-related belief or at the behest of MO. Address correspondence to: Brian Holoyda, MD, MPH, Depart- a charismatic leader. Could an individual’s participa- ment of Psychiatry and Behavioral Sciences, University of California, Davis School of Medicine, 2230 Stockton Boulevard, Sacramento, CA tion in a murder be considered the result of a fixed, 95817. E-mail: [email protected] false belief that developed in response to cult involve- Disclosures of financial or other potential conflicts of interest: None. ment? When cult-related beliefs or cult leaders’ com- Volume 44, Number 1, 2016 53 Killer Cult Members and the Insanity Plea mands become part of a person’s belief structure and members and their attorneys have raised NGRI pleas behavior, do we consider them psychotic? These and the courts have been forced to decide whether questions have obvious relevance in the courtroom cult beliefs represent religious conviction or psy- when cult members stand trial for murder. chotic delusions. These court decisions provide an- The Diagnostic and Statistical Manual of Mental swers to questions posed by Joshi et al.4 and guidance Disorders has provided limited guidance in deter- for forensic evaluators responsible for forming opin- mining the answers to these questions. The Fourth ions regarding criminal defendants involved in cult- Edition, Text Revision (DSM-IV-TR)5 recognized related litigation. the diagnosis of shared psychotic disorder (or folie a` deux), but the criteria and supportive text did not Existing Case Law address religious beliefs or cults. DSM-5 does not We searched the LexisNexis database for all re- include shared psychotic disorder, but instead has ported federal and state cases involving cult-related “delusional symptoms in [the] partner of [an] indi- murder phenomena that reached appellate review. vidual with delusional disorder” (Ref. 6, p 122), First, we searched using the terms “cult” and “mur- within other specified schizophrenia spectrum and der,” which yielded 398 cases. In our search, we did other psychotic disorder as a diagnosis for an individ- not attempt to define cult, but determined for each ual who, in the context of a relationship, receives case whether a cult or religious sect had significant delusional content from a dominant partner but may involvement in a murder, defined as murder second- not entirely meet criteria for delusional disorder. The ary to either a cult leader’s directives or the cult’s text associated with the diagnosis of delusional disor- alleged beliefs. We then identified whether a mental der in DSM-5 indicates that “an individual’s cultural illness defense such as NGRI or not criminally re- and religious background must be taken into account sponsible was put forth at trial or raised as an issue on in evaluating the possible presence of delusional dis- appeal (e.g., because of counsel’s failure to press a order” (Ref. 6, p 93). It is unclear to what degree mental health defense at trial). Of the 398 cases re- “cultural and religious background” could include viewed, there were 8 such unique cases of cult-related participation in a cult. The outline for the cultural murder. See Table 1 for a summary of these cases. formulation in DSM-IV-TR and the complete cul- tural formulation in DSM-5 likewise provide no People v. Manson guidance for evaluators when distinguishing between Perhaps the most well-known series of cult-related delusional beliefs and religious convictions. murders are those that Charles Manson and his The Supreme Court heard one of the earliest cases “Family” committed in the 1960s.9 Mr. Manson and involving cult-related beliefs. In United States v. Bal- many of his Family members engaged in successive lard (1944),8 the organizers of the I Am movement multiple homicides with the purpose of starting a appealed their conviction for defrauding people by race war that they termed “Helter Skelter,” which claiming to have supernatural powers to heal incur- would ultimately benefit the Family. The Family is able diseases. The Court held that the question of notorious because of its charismatic leader Charles whether the defendants’ claims about their religious Manson; the intensity of mind control by drugs, vi- experiences were valid should not have been given to olence, and fear that he exerted; and the bizarre be- the jury because the “freedom of religious belief . liefs preached by him and his followers. The Family embraces the right to maintain theories of life and of members believed in a variety of odd teachings, such death and of the hereafter which are rank heresy to as Helter Skelter, the prophesied apocalyptic war that followers of the orthodox faiths” (Ref. 8, p 5). In his would result from interracial tension between blacks dissent, Justice Robert Jackson suggested that the and whites, and that message of the war to come was case should have been dismissed outright for being foretold and spread to others by the Beatles’ White nearly tantamount to an investigation into the truth Album. Despite the extraordinary grip that Mr. Man- of a religious conviction. son had on his followers, or perhaps because of it, the Although the Supreme Court deferred passing Family members did not put forth a plea of NGRI. judgment on a cult’s beliefs in United States v. Bal- People v. Manson appeared in the LexisNexis search lard, lower courts have dealt with cult members who and bears mentioning because, even though the case have engaged in murder. In some of these cases, cult was rife with bizarre details that were popularized 54 The Journal of the American Academy of Psychiatry and the Law Holoyda and Newman Table 1 Summary of Cases Defendant NGRI NGRI Year of Cult Leader Defense Defense Case Murder or Member Raised Successful Diagnoses People v. Manson9 1969 Both No N/A Nebraska v. Michael Ryan10 1985 Leader Yes No Paranoid schizophrenia Nebraska v.