Dissociative Identity Disorder and Criminal Law | jcarlsmith | August 30, 2012

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Dissociative Identity Disorder and Criminal Law

by jcarlsmith Show/Hide
This module presents a case study in the intersection of law, philosophy, and clinical psychiatry. Its focus is on the legal questions raised by a psychological disorder known as Dissociative Identity Disorder (formerly known as Multiple Personality Disorder). Persons afflicted with this disorder have one or more distinct personalities, each with different behavior patterns, values, memories, and self-concepts. These personalities (known as “alters”) alternate in exerting full control over the body, and there are often amnesic barriers between the dominant, “host” personality and the alters that recurrently take over. Such a strange disorder raises many questions, but for our purposes, the most important one is this: how should the criminal justice system try and punish people with DID who commit crimes while an “alter” is in control? As we’ll see, this relatively narrow question quickly forces us to grapple with foundational issues surrounding the nature of person-hood, the attribution of responsibility, and the relationship between our legal system and the evolving field of clinical psychiatry. EDIT PLAYLIST INFORMATION DELETE PLAYLIST

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  1. 1 Show/Hide More Psychological Background
    Original Creator: jcarlsmith
    This playlist provides materials that lend insight into the psychological dimensions of Dissociative Identity Disorder. It includes diagnostic criteria, first-person descriptions of the disorder, a section of a documentary about DID, and a summary of the debate surrounding multiplicity during the past decades. Of course, given the vastness of the literature on DID, the psychological picture offered by this playlist is extremely limited. The goal is not to plumb the depths of DID's history, or to resolve debates about its nature and diagnosis. Rather, it is to offer a glimpse of the complexity of this multifaceted disorder, and to help make concrete the legal and philosophical puzzles it poses — puzzles that will be explored in more depth later in the module.
    Notes:
    This playlist provides materials that lend insight into the psychological dimensions of Dissociative Identity Disorder. It includes diagnostic criteria, first-person descriptions of the disorder, a section of a documentary about <span class="caps">DID</span>, and a summary of the debate surrounding multiplicity during the past decades. Of course, given the vastness of the literature on <span class="caps">DID</span>, the psychological picture offered by this playlist is extremely limited. The goal is not to plumb the depths of DID's history, or to resolve debates about its nature and diagnosis. Rather, it is to offer a glimpse of the complexity of this multifaceted disorder, and to help make concrete the legal and philosophical puzzles it poses &#8212; puzzles that will be explored in more depth later in the module.
    1. 1.1 Show/Hide More Official Diagnostic Criteria for Dissociative Identity Disorder

      These are the official diagnostic criteria for Dissociative Identity Disorder, as outlined in the updated Diagnostic and Statistical Manual of Mental Disorders (DSM-V).

      (last accessed 9/30/12)

      Notes:
      Take a minute to fill out the diagnostic worksheet provided by the <span class="caps">APA</span> (under the tab labeled &#8220;severity&#8221;). How frequently do you manifest symptoms associated with <span class="caps">DID</span>? Keep your answers in mind as you are introduced to people with diagnosed cases of <span class="caps">DID</span> later in the module. Are we all &#8220;multiple&#8221; to some extent? Or are there genuinely sharp distinctions between standard fluctuations in personality on the one hand, and <span class="caps">DID</span> on the other?
    2. 1.2 Show/Hide More First-person Descriptions of DID
      Original Creator: jcarlsmith
      Notes:
      This mini-playlist provides written, first-person descriptions of <span class="caps">DID</span>. The goal is to offer a sampling of the diverse ways in which <span class="caps">DID</span> manifests, and to help the reader begin thinking about the legal relevance of how exactly we conceive of the experience (or experiences) of <span class="caps">DID</span>.
      1. 1.2.1 Show/Hide More Billy Milligan
        Notes:
        Milligan's description emphasizes the separation between the different identities involved in <span class="caps">DID</span>. The host identity simply disappears, an alter takes over for a while, and then the host re-appears somewhere else having &#8220;lost that time.&#8221; As we'll see, however, this is by no means a universal experience of the relationship between the host personality and the alters. In other cases, different personalities can be co-conscious, they can communicate, and they can coordinate their responses to situations. As you move through the module, keep in mind the manner in which our conception of the relationship between the alters affects our conception of their criminal responsibility.
      2. 1.2.2 Show/Hide More Anonymous
        Notes:
        Note the difference between this description and the one Milligan gives. Milligan claims total separation between the identities &#8212; an utter absence of consciousness, and then a re-appearance at a different time. The anonymous &#8220;survivor,&#8221; however, suggests that at times he or she is &#8220;watching&#8221; her body, but unable to control it. That is, she remains conscious, but at some kind of distance from her standard capacity for agency.
      3. 1.2.3 Show/Hide More John Woods
        This is an article written by Judith Armstrong, a psychologist assigned as an expert witness in the trial of a man — John Woods — whom she had diagnosed with DID. Mr. Woods had killed his girlfriend, Sally, during an argument about her faithfulness. Read Section IV: The Interview (pp. 212-216). In it, Dr. Armstrong conducts separate interviews with the three alters involved in the crime.
        Notes:
        This is the lengthiest of the descriptions given thus far, and it reveals the complexity of the dynamics that develop between the alters. Note, for example, that Ron &#8220;overhears&#8221; what John is saying to Sally (p. 213); that Donnie knows who Dr. Armstrong is because &#8220;that information got<br /> passed around&#8221; (p. 214); that Donnie wants to &#8220;ask&#8221; Ron what is going on, but Ron &#8220;won't talk to him&#8221; (p. 214); that Donnie tries to impress Ron and John by jumping off a balcony (p. 215); that John and Donnie both think that Ron is &#8220;usually right&#8221; (p. 215 and p. 216). All of this suggests not just internal communication and co-consciousness, but an intricate network of relationships and power dynamics operating amongst the alters.
    3. 1.3 Show/Hide More Barb's Life
      This is a documentary about three different people with DID. The whole film is fascinating, but the section to focus on starts at 38:37 and runs through the end of the film, about 20 minutes. It introduces you to Barb – a woman with multiple personality disorder -, her family, and a number of her alters.
      Notes:
      The alter named &#8220;Cary,&#8221; introduced at 50.23, is of particular interest, since Cary is one of the alter who often does illegal and destructive things when she is &#8220;out.&#8221; For example, towards the end of the film, Cary has written $1500 worth of bad checks to pay for a reckless shopping spree. Barb has no memory of the incident, but her husband needs to take out a loan in order to pay for them. This is exactly the type of situation in which multiples in the court system often find themselves. As you watch, note your initial reactions: to what extent does it seem to you that Barb is responsible for Cary's actions? Also note the manner in which Cary speaks about her own situation. &#8220;How would you feel if you were in my position? I'm stuck here. I don't have a life.&#8221; (53:11) An alter asking for empathy raises interesting questions. What is it like to &#8220;be&#8221; an alter? Is that even a sensible question, separate from the question of what it is like to &#8220;be&#8221; Barb?
    4. 1.4 Show/Hide More Skepticism about DID
      Notes:
      <p>Controversy over <span class="caps">DID</span> in the psychiatric community is longstanding, and the kind of skepticism about <span class="caps">DID</span> that Tozman and Padis express remains relatively common. Skeptics point to a number of factors that could raise questions about DID's legitimacy. First, the diagnoses of <span class="caps">DID</span> has undergone significant changes in the past half-century. Prior to 1970, there had only been about 100 cases of <span class="caps">DID</span> reported worldwide (Schacter, Gilbert, and Wegner). However, in the latter decades of the 20th century, the number of reported cases skyrocketed. Maldonado &amp; Butler (1998), for example, estimate that between .5% and 1% of the general population now suffers from the disorder. What accounts for this rapid increase? Skeptics suggest that increased publicity around the disorder (for example, the 1957 film The Three Faces of Eve) has led to conscious or un-conscious simulation, and that eager psychotherapists &#8211; using a combination of suggestion, hypnosis, and expectation &#8211; have created symptoms of <span class="caps">DID</span> in their clients or elicited false reports of child abuse or <span class="caps">DID</span>-like behavior. These doubts are buttressed by the fact that childhood trauma and abuse is common around the globe, particularly among people of low-income, yet <span class="caps">DID</span> is diagnosed most frequently among middle-class north americans (Acocella, 1999).</p> <p>In response to such skepticism, believers in <span class="caps">DID</span> point to the relative success of <span class="caps">DID</span> treatments in eliminating symptoms in patients who did not response to treatment for bi-polar disorder or schizophrenia (see Saks, 402). They point to studies independently verifying the correlation between child abuse and <span class="caps">DID</span> (without reliance on the patient's memories), the relative consensus in the psychiatric community about the symptoms and treatment of <span class="caps">DID</span> (as evidenced by its inclusion in <span class="caps">DSM</span>), and recent evidence that <span class="caps">DID</span> may not be as bound to North America as previously supposed (Sar, Yargic and Tutkun (1996)).</p> <p>There is much to be said on both sides, and debate about <span class="caps">DID</span> will likely continue well into the future. For the purposes of this module, however, we need not resolve the debate here. Few skeptics about <span class="caps">DID</span> deny the existence of the disorder in its entirety. Rather, they tend to question its frequency and its status in relation to other disorders like schizophrenia. Thus, even if <span class="caps">DID</span> is significantly over-diagnosed, the legal questions this module investigates will still be raised by the minority of cases in which the diagnosis is accurate. Moreover, if the reader is unwilling to grant the legitimacy of even a single case of <span class="caps">DID</span>, he or she can view the central purpose of this module as a hypothetical: if <span class="caps">DID</span> were a real disorder, how would the legal system need to handle it? But such caveats are, at least in my view, relatively unnecessary, given the implausibility of supposing that every single case of <span class="caps">DID</span> has been faked, created by therapy, or mis-reported.</p> <p>Sources:<br /> Acocella, Joan (1999). Creating Hysteria: Women and Multiple Personality Disorder. New York: Jossey-Brass.<br /> Saks, Elyn (1991). Multiple Personality Disorder and Criminal Responsibility, 25 U.C. Davis L. Rev. 383.<br /> Maldonado, J. R., Butler, L. D., &amp; Spiegel, D. (1998). Treatments for dissociative <br /> disorders. In P. E. Nathan &amp; J. M. Gordon (Eds.), A Guide to Treatments that <br /> Work (pp. 423-446). New York: Oxford University Press.<br /> Sar, V., Yargic, L., &amp; Tutkun, H. (1996). Structured interview data on 35 cases of dissociative identity disorder in Turkey. American Journal of Psychiatry, 153 (10), 1329-1333. <br /> Schacter, D. S., Gilbert, D. T., &amp; Wegner, D. M. (2008). Psychology. New York: Worth.</p>
  2. 2 Show/Hide More Philosophical Background
    Original Creator: jcarlsmith
    This playlist provides a brief introduction to the contemporary philosophical debate surrounding the nature of personal identity. Again, the goal is not to resolve the debate (though the “Mad-Scientist” test is meant to prompt the reader's personal intuitions), but rather to provide the reader with the background necessary to understand the ways in which the philosophical assumptions we bring to our understanding of DID will directly impact our legal conclusions.
    Notes:
    This playlist provides a brief introduction to the contemporary philosophical debate surrounding the nature of personal identity. Again, the goal is not to resolve the debate (though the &#8220;Mad-Scientist&#8221; test is meant to prompt the reader's personal intuitions), but rather to provide the reader with the background necessary to understand the ways in which the philosophical assumptions we bring to our understanding of <span class="caps">DID</span> will directly impact our legal conclusions.
    1. 2.1 Show/Hide More Understanding the Persistence Question
      There is a person sitting at your computer right now, reading these words. Earlier today, there was (probably) a person that got out of your bed, brushed his or her teeth, and ate breakfast. What makes these two people both “you”? Or, more generally, what has to be the case for a person in the past to be identical to a person in the future? This is a summary of some of the central issues involved in attempting to answer this question. Start at Section 2: “Understanding the Persistence Question,” and read through Section 5: “Fission.”
    2. 2.2 [This resource no longer exists on H2O because its owner deleted it.]
    3. 2.3 Show/Hide More What, exactly, is a "self"?
      This is an article about DID and self-hood, written Nicholas Humphrey, a theoretical psychologist, and Daniel C. Dennett, a contemporary (and relatively famous) philosopher of mind. Start at the bottom of page 6 (“Many people who find it convenient…”) and read through the middle of page 12 (“we shall be able to come closer to an answer…”).
      Notes:
      <p>Humphrey and Dennett describe two conceptions of self-hood &#8212; a &#8220;layman's&#8221; view, according to which there is a real thing called a &#8220;self&#8221; or a &#8220;soul&#8221; that thinks thoughts, controls actions, holds memories, etc; and a &#8220;revisionist&#8221; view, according to which selves are explanatory fictions, used to talk about complex systems at a certain level of description, but non-existent in some ultimate sense. Does their attempt at an analogy with American Democracy succeed in bridging the two views?</p> <p>More importantly, to what extent is the &#8220;layman's&#8221; conception of the self &#8211; which ascribes to people a &#8220;soul-like agency&#8221; -embedded within our criminal justice system? What would a justice system that reflected the &#8220;revisionist&#8221; conception of the self look like? Could we justly hold &#8220;centers of narrative gravity&#8221; or &#8220;ways of talking about complex systems&#8221; responsible for murders or rapes? Can we mete out punishments based on an &#8220;explanatory fiction&#8221;? These are large questions in legal philosophy that cannot be answered here. Yet the challenge of prosecuting defendants with <span class="caps">DID</span> quickly begins to raise them in earnest.</p>
  3. 3 Show/Hide More Multiples as Perpetrators
    Original Creator: jcarlsmith
    This playlist gathers together a set of seminal cases in which people with DID were tried for crimes committed while at least one alter was “out” and in control. It examines the different legal standards courts have used to evaluate such cases, and it offers a number of secondary materials to aid in applying critical scrutiny to the issues at hand.
    Notes:
    This playlist gathers together a set of seminal cases in which people with <span class="caps">DID</span> were tried for crimes committed while at least one alter was &#8220;out&#8221; and in control. It examines the different legal standards courts have used to evaluate such cases, and it offers a number of secondary materials to aid in applying critical scrutiny to the issues at hand.
    1. 3.1 Show/Hide More State v. Grimsley
      Original Creator: jcarlsmith
      Are the actions of a person with multiple personality disorder voluntary when she is dissociated from her primary personality and in the state of a consciousness of a secondary personality?
      Notes:
      This 1982 opinion set a legal standard for rulings pertaining to <span class="caps">DID</span> that many other courts have relied upon in ensuing cases. Thus, it is worth examining quite closely. Appellant was convicted of drunk driving. She appealed on the grounds that one of her alter personalities was in control at the time of the incident, and that her actions were therefore neither conscious nor voluntary. Note especially the court's framing of the incident in the last two paragraphs of the opinion. What philosophical and psychological assumptions about <span class="caps">DID</span> are at work? Do you agree with the court that if you allow the memory barriers involved with <span class="caps">DID</span> to aid in Grimsley's defense, you would have to do the same with all defendants whose memories are blocked? And is it really &#8220;immaterial whether [Grimsley] was in one state of consciousness or another,&#8221; as long as the alter in control was sane?
    2. 3.2 Show/Hide More Kirkland v. State
      Original Creator: jcarlsmith
      Does DID on its own constitute a legitimate basis for an insanity defense?
      Notes:
      This 1983 case makes clear the influence of the standard set by the Grimsley court in 1982. The fact patterns were quite similar: appelant robbed a bank, then pled not guilty by reason of insanity on the basis of an uncontroverted diagnosis of &#8220;psychogenic fugue,&#8221; a disorder so closely akin to <span class="caps">DID</span> that the court treats them as identical. The court primarily relies on reasoning from Grimsley, and continues to develop analogies to somnambulism, memory loss, and unconscious action. As you read through the opinion, do you see any significant differences between this case and Grimsley, that might motivate a difference in legal response?
    3. 3.3 Show/Hide More United States v. Denny-Schaffer
      Original Creator: jcarlsmith
      Faced with a defendant diagnosed with DID, did the trial judge err in rejecting the insanity defense for insufficiency of the evidence thereon?
      Notes:
      Unlike Kirkland, this 1993 opinion represents a direct repudiation of the standard set by the Grimsley court. Defendant was convicted of kidnapping a child from a New Mexico hospital. She pled not guilty by reason of insanity, claiming that her host personality was not in control at the time of the crime. Look closely at the court's reasoning in Part IV. Do the court's philosophical assumptions about <span class="caps">DID</span> differ from those at work in Grimsley and Kirkland? What new standard does this opinion suggest? Do you think that the court has done enough to justify it?
    4. 3.4 Show/Hide More Parker v. State
      Original Creator: jcarlsmith
      Did the trial judge err in finding that a defendant with DID had failed to prove her insanity?
      Notes:
      Defendant &#8211; Pam Parker &#8211; pursued a check &#8220;kiting&#8221; scheme at two local banks. She pled insanity because of her &#8220;split personality,&#8221; and claimed that her other personality, Pam Lease, was the one responsible. The court affirmed the trial judge's ruling that there was insufficient evidence that defendant was insane. This case is of interest primarily because one of the leading scholars of <span class="caps">DID</span> and criminal law &#8211; Elyn Saks, who you will be reading later in the module &#8211; finds in it receptivity to the idea that it may not have been Pam Parker who committed the crime at all, but rather Pam Lease who did it (See Saks (1992), p. 386). With this view presumably comes the idea that different alters are separate people, and should be treated as such by the court (a position that Saks herself endorses in Section II of her article). Read through the case, and see if you see in it the same thing Saks does.
    5. 3.5 Show/Hide More State v. Rodrigues
      Original Creator: jcarlsmith
      Has the state presented sufficient evidence of the defendant's sanity so as to require that the issue be presented to the jury?
      Notes:
      Appelant was indicted for three counts of sodomy and one of rape. A judge acquitted him on the basis of his <span class="caps">DID</span>, and the state appealed. Note the manner in which the differing views of the psychologists involved influence the outcome of the case. In the face of such disagreement, do you think that putting the issue to the jury is an appropriate response? More importantly, what standard does the opinion set for how to approach defendants with <span class="caps">DID</span>, and how does it differ from both the standards set in Grimsley and in Denny-Schaffer?
    6. 3.6 Show/Hide More State v. Greene
      Original Creator: jcarlsmith
      Is dissociative identity disorder (DID) admissible as evidence of insanity or diminished capacity?
      Notes:
      Defendant was charged with kidnapping and sexually assaulting his therapist, who had been treating him for <span class="caps">DID</span>. He pled not guilty by reason of insanity. The Supreme Court of Washington had already addressed a virtually identical issue in State v. Wheaton, 121 Wash.2d 347, 850 P.2d 507 (1993), but it agreed to hear this new case en banc anyways. This case is notable for the depth of its analysis of the issues involved. It also touches directly on broader questions about the way in which courts should relate to ignorance and uncertainty in the medical community. How does the court's ruling differ from the rulings in Grimsley and in U.S. v Denny-Schaffer? Do you agree that it is not possible to reliably connect the symptoms of <span class="caps">DID</span> with the sanity or insanity of the defendant? If so, do you think that the court's response to such impossibility is appropriate?
    7. 3.7 Show/Hide More State v. Darnell
      Original Creator: jcarlsmith
      Is there sufficient evidence in the record to raise an issue as to whether a defendant with DID was responsible for the murder of his father?
      Notes:
      Defendant was convicted for the murder of his father. He claimed that his father had consented to the killing, and that he was not guilty by reason of mental defect due to <span class="caps">DID</span>. This is case is notable primarily because it appeals explicitly to the possibility of the defendant faking his disorder &#8212; a possibility that was made salient by the controversy surrounding the diagnosis of <span class="caps">DID</span> around that time (see the Skepticism about <span class="caps">DID</span> section of this module).
    8. 3.8 Show/Hide More Secondary Materials
      Original Creator: jcarlsmith
      This playlist provides secondary materials to aid in the analysis of criminal cases involving defendants diagnosed with DID.
      Notes:
      This playlist provides secondary materials to aid in the analysis of criminal cases involving defendants diagnosed with <span class="caps">DID</span>.
      1. 3.8.1 Show/Hide More Multiple Personality Disorder and Criminal Responsibility
        This is a seminal article in the narrow field of DID and Criminal Law. In it, Elyn Saks presents three different interpretations of DID, and argues that according to each of them, multiples should be deemed non-responsible for their crimes. Read the intro (pp. 384-389), and then read sections II-IV (pp. 403-442).
        Notes:
        Which of the three interpretations of <span class="caps">DID</span> do you find most persuasive? Do you agree with Saks that each renders multiples non-responsible? Note the contrast between the way she appeals to an analogy with sleepwalking in Section <span class="caps">III</span>, and the way the Grimsely and Kirkland courts do so. In addition, pay particular attention to Section II, in which Saks argues that the best interpretation of <span class="caps">DID</span> views alters as separate people. By this point in the module, you should be familiar with some of the philosophical arguments she employs. Are you convinced? You'll notice from the cases reviewed in this playlist that not a single court has been willing to follow her in this conclusion. What explains this reluctance? Are certain philosophical positions simply untenable from a legal perspective, regardless of their persuasiveness in the abstract?
      2. 3.8.2 Show/Hide More Criminal Law and Multiple Personality Disorder: Vexing Problems of Personhood and Responsibility
        This article, written by the philosopher Walter Sinnott-Armstrong and the psychiatrist Stephen Behnke, aims primarily to challenge the argument that Saks pursued in Section II of her article (see above). It does so through appeal to certain experiential memories shared between alters. The beginning of the article provides a concise and informative summary both of Sak's position and of the different jurisprudential standards we have been exploring in this playlist. However, the essential material only really begins in Section IV (p. 282), so if you are strapped for time, start there and read through the end (p. 296).
        Notes:
        What do you think about the article's appeal to experiential memories shared between alters as a means of establishing their identity? Is it a problem that, as the authors admit, this kind of criterion will be extremely difficult to investigate? What's more, have Armstrong and Behnke really shown all they need to show? For example, they claim that in the Grimsley case, both Robin and Jennifer presumably have a memory of being told about the lump in the body's breast. Suppose we grant this conclusion. Does it follow that each alter has the same memory? After all, Armstrong and Behnke accept the possibility of co-consciousness between the alters. As we saw early in the playlist, in the description of the relationship between John Wood's alters, different alters may perceive events quite differently. Indeed, they seem to do in the manner that different people do &#8212; namely, in relationship to their own projects, concerns, relationships, etc. Does this pose a problem for Armstrong and Behnke? If so, what do you think would be their strongest response? Finally, suppose we grant to Armstrong and Behnke that alters are parts of the same person, and not separate people as Saks claims. Have they given sufficient due to Saks' arguments that even so understood, multiples would still be non-responsible? Armstrong and Behnke only address that question in the last paragraph of the essay, in which they embrace the Grimsley court's standard. Look closely at this paragraph. Is it persuasive?
  4. 4 Show/Hide More Multiples as Victims
    Original Creator: jcarlsmith
    The majority of this module has been devoted to assessing the criminal responsibility of people with DID who commit crimes. However, this relatively narrow focus by no means exhausts the legal questions raised by DID and its variants. To leave the reader with a small taste of other issues that need to be addressed, this playlist documents a case related to the capacity of multiples to consent to sex. The goal is not to address this issue with any depth, but rather to point beyond it towards the many questions this short survey leaves unanswered.
    Notes:
    The majority of this module has been devoted to assessing the criminal responsibility of people with <span class="caps">DID</span> who commit crimes. However, this relatively narrow focus by no means exhausts the legal questions raised by <span class="caps">DID</span> and its variants. To leave the reader with a small taste of other issues that need to be addressed, this playlist documents a case related to the capacity of multiples to consent to sex. The goal is not to address this issue with any depth, but rather to point beyond it towards the many questions this short survey leaves unanswered.
    1. 4.1 Show/Hide More State v. Peterson
      This is an article from the Journal of Forensic Psychiatry (Volume 9, No. 2, September 1998), written by Dr. David James. In it, Dr. James discusses a famous case – State of Wisconsin v. Mark A. Peterson – in which a woman with DID claimed that she had been raped by a local man. The defendant responded that one of the woman's alter – a fun-loving personality called “Jennifer” – had consented to the act. Read starting from the second paragraph of Section III (“the giving of evidence in court…”) through the end of Section III.
      Notes:
      This case will likely be remembered more for its status as a media circus than for its jurisprudential significance. Nevertheless, it serves to illustrate the ways in which questions about the agency, identity, and responsibility of multiples do not stop once the multiples refrain from committing crimes. In particular, this case raises the question of whether and how an alter can assent to sex using a body all the alters share (think back to Barb's relationship to her husband). Similar questions can be raised about other kinds of consent. Can alters make contracts? Should they be sworn in separately? Must the confidentiality of each alter be respected by doctors and therapists? These questions are complicated, of course, by longstanding questions about the relationship between sanity and responsibility more generally. The strange and dramatic nature of <span class="caps">DID</span>, however, makes them all the more acute.
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May 21, 2013

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