Reichert Et Al 2015

International Journal for the Study of New Religions 6.
1 (2015) 3–26
ISSN 2041-9511 (print) ISSN 2041-952X (online)
doi:10.1558/ijsnr.v6i1.22186
“Brainwashing”:
Diffusion of a Questionable Concept in Legal Systems
Jenny Reichert,1 James T. Richardson,2 and Rebecca Thomas2
Heidelberg University, 2University of Nevada, Reno

1
jennyrreichert@gmail.com
Abstract
The idea that an individual could be manipulated into performing acts
“against their will” created a fear of “brainwashing” and, specifically, new
religious movements (NRMs). Courts in the United States initially accepted
evidence concerning “brainwashing” in cases involving NRMs, and subse-
quently the term has been applied in situations involving other behaviors
labeled as deviant both in the U.S. and other societies. This has generated
challenges for legal systems despite the inability of brainwashing-based claims
to meet requirements for admissibility as scientific evidence. Brainwashing-
based claims have diffused into other areas of the American legal system,
including, for example, custody cases involving allegations of Parental Aliena-
tion Syndrome (PAS) as well as in cases involving terrorism. This report pre-
sents data on how brainwashing has been treated historically in American
legal cases and its current uses within that justice system.
Keywords
brainwashing, scientific evidence, New Religious Movements (NRMs), cults,
Parental Alienation Syndrome(PAS), diffusion of innovation, terrorism, CIA
Introduction
Theories of “brainwashing” were willingly accepted in United States’ courts
as viable explanations in courts of law dealing with cases involving new reli-
gious movements (NRMs) and seemingly psychologically coerced conversion
and recruitment (Anthony 1990, 1999; Richardson 1991, 1993; Introvigne,
2014; Richardson 2014). As will be discussed below, these theories represent
© Equinox Publishing Ltd. 2015, Office 415, The Workstation, 15 Paternoster Row, Sheffield, S1 2BX
4 Jenny Reichert, James T. Richardson and Rebecca Thomas
a significant misunderstanding and misuse of the concept “brainwashing,”
which was originally developed a propagandistic explanation of what hap-
pened in China when the Communist party took over, and what led to a few
American POWS in North Korea remaining there for a time after the war.
The pervasive notion that an individual could be manipulated into perform-
ing acts “against their will” created a fear in the public concerning brainwash-
ing and this fear was focused specifically on NRMs that developed first in
America in the late 1960s and early 1970s (Fort 1985). The term has become
more widely known, both in the U.S. and other societies (Richardson 1996;
Anthony 1996; Richardson and Introvigne 2001), in part because of being
applied to NRMs, and it has increasingly been applied to a number of situ-
ations that involved unpopular, controversial, or allegedly deviant behavior.
This expanded usage has translated into challenges for legal systems, despite
the inability of the idea of “brainwashing” to meet formal requirements for
admissibility as scientific evidence (Anthony 1990; Anthony 1996; Anthony
and Robbins 1992, 1995; Richardson 1991, 1993, 1994, 1996; Richardson
et al. 1995; Ginsburg and Richardson 1998).
The diffusion of evidentiary innovations such as “brainwashing” by the
courts illustrates problems that many judges have in determining the sci-
entific merits of proffered evidence that claims to be scientific (Gatowski et
al. 1997, 2001; Dobbin and Gatowski 1998; Dobbin et al., 2002). Thus,
although “brainwashing” claims have not been used as often in recent cases
involving NRMs, as demonstrated herein, these claims derived from NRM
controversies have diffused into other types of cases, including criminal, civil,
and specialty court cases, especially family courts. As will be shown, claims
involving “brainwashing” have also surfaced in public discussions and legal
cases involving terrorism, especially when recruitment to radical Islam is the
focus of attention. The following discussion examines how brainwashing has
been treated historically within the U.S. legal system, and then examines how
the concept has been diffused within the legal arena and in public discourse.
It is hoped that this report will encourage further research within the U.S.
and in other countries about how brainwashing-based theories have spread
and are being used in legal systems, and in new areas of public concern.1
1. There is research demonstrating how psychological syndromes have spread from Amer-
ica to other societies such as England, Canada, and Australia. See Gatowski et al. (1997),
Gatowski et al. (1996), and Dobbin and Gatowski (1998). As already noted, the concept
of brainwashing has spread rapidly to other societies (Anthony 1999; Richardson 1996;
Richardson and Introvigne 2001). For instance, a search through the records of the High
Court of Australia revealed two cases that reference brainwashing specifically, including one
© Equinox Publishing Ltd. 2015

“Brainwashing” 5
The origins of “brainwashing”
The concept of “brainwashing” was first introduced into American culture as
part of an ideological war between the United States and Communist China
to explain supposed radical behavioral changes in Chinese citizens as a result
of participating in Communist thought reform camps (Anthony 1990, 1996,
1999; James 1986; Richardson and Kilbourne 1983; Solomon 1983). It was
described as a method of altering a person’s basic beliefs and personality in
an effort to train them as deployable agents through “psychological coer-
cion” (Richardson 1993), and supposedly included successful manipulation
of individuals so that they would join groups or commit acts that they would
otherwise not countenance. Indeed, the technique was sometimes treated as
more powerful than physical coercion (Richardson 1991, 64). “Brainwash-
ing,” as used in NRM legal cases, assumes that an individual’s free will can be
stripped and new belief patterns imposed. This interpretation of “brainwash-
ing,” as demonstrated by Anthony (1990, 1996, 1999) and others (James
1986), relies on a propagandistic view of the concept and misrepresents the
work of two key scholars, Robert J. Lifton (1961) and Edgar Schein and
colleagues (1961), whose work has been used to undergird applications of
the concept to NRMs. This view of “brainwashing,” which Anthony (1996,
1999; also see Melton 2000) refers to as the “CIA” or “robot” brainwash-
ing perspective, (see details below) explicitly violates the idealistic American
value of individualism, which emphasizes autonomy and personal choice. As
this version of brainwashing theory became more well-known, fear that a reli-
gious group could overpower free will and impose their strange belief system
on the youth of the society grew in the general public (Bromley and Breshel
1992; Richardson 1992), leading to a “moral panic” about these new groups
(Richardson and Introvigne 2007).
Public fear of “brainwashing” was strengthened by the incorporation of
the concept into popular media such as television programs, and with the
release of films such as Manchurian Candidate, which reinforced the idea
that American citizens were powerless against psychological weapons devel-
oped by Communists. Legal cases such as the media-sensationalized trial
of Patty Hearst in the mid-1970s also contributed to increasing concern
about “brainwashing” (Fort 1985; Richardson and Thomas 2002; Richard-
son 2014, 2015). Hearst’s defense of brainwashing in her murder trial was
dealing with Scientology and another that refers to the alienation of a child during a custody
proceeding as recent as 1994. However, further research is needed on how this questionable
concept has permeated other legal systems and the various ways in which it has been used.

initially unsuccessful, and she spent some time in prison before being par-
doned (Richardson 2015). However by this time, the public had become
convinced that this understanding of the term “brainwashing” had scientific
merit, and as a result, “brainwashing” entered the common lexicon. The term
has been used casually by public figures and ordinary people alike, including
in other nations, with them sometimes unaware that it had been developed
only recently, and that it carried a heavy ideological connotation (Anthony
1990, 1996; James 1986, 242; Richardson and Kilbourne 1983; Richardson
1993). The concept also diffused around the world, and has been used in
legal cases and legislative actions concerning minority religions (Richardson
1996; Richardson and Introvigne 2001; Anthony 1999).
However, as shown in the thorough analyses offered by Dick Anthony
(1990, 1996, 1999; also see James 1986 and Melton 2000; Solomon 1983
and Richardson and Kilbourne 1983), the interpretation of “brainwashing”
promoted by those opposed to NRMs was a serious misrepresentation of the
work of two key scholars, Robert J. Lifton and Edgar Schein, who had stud-
ied what happened in China when the communists assumed control and in
North Korea when a few American GIs decided not to return directly home
after the Korean war was over (Lifton 1961; Schein et al. 1961). However,
the interpretations of Lifton and Schein of these much-publicized events has
been overwhelmed by adoption of a view of what happened promoted earlier
by Edward Hunter, a CIA operative who wrote two books about results of the
communist takeover in China (Hunter 1951, 1960) .
Hunter coined the term “brainwashing” and his interpretation became the
commonly accepted view of what was happening to citizens in China and what
had occurred with the few GIs who refused, as least initially, to be repatriated
after the Korean War was over. Hunter claimed that what had occurred within
China was directly derivative of the work of Russian scientist Ivan Pavlov who
had demonstrated how dogs could be conditioned using certain techniques.
Hunter claimed that the Russians had developed powerful techniques based
on Pavlov that had been used in the Russian purge trials of the 1930s, and
then had shared the techniques with the Chinese who had then applied those
techniques in the resocialization of Chinese citizens after the takeover. Hunter’s
efforts were promoted by other widely read treatments of this allegedly new set
of techniques that could condition human being to dramatically change their
beliefs and behaviors (Meerloo 1956; Sargent 1957). This ideologically derived
explanation, which has come to be called the “robot” or “evil eye” view of
personal change (James 1986; Anthony and Robbins 1992; Melton 2000) was
readily accepted in the anti-communist paranoia of the 1950s in America. The

process involved several inter-related methods to overcome the free will of the
target person (Anthony 1990, 307–316), including “conditioning,” “debilita-
tion,” “deception/defective thinking,” and “dissociation-hypnosis-suggestibil-
ity.” There are other ways to characterize the allegedly powerful psycho-social
techniques that the communists had developed (see Richardson and Kilbourne
1983; Solomon 1983; James 1986), but there is no doubt that various ver-
sions of these processes came to dominate public discussions and public pol-
icy debates about the threat of communism during the 1950s and 1960s in
America. The more sophisticated work was done by Lifton and Schein, both
of whom have since taken issue with how their work has been expropriated by
those opposed to NRMs (James 1986, 249; Anthony 1990, 300–301). How-
ever the “genie is out of the bottle,” and cannot easily be returned. Both Lifton
and Schein have been cited by those opposed to NRMs in legal and public
battles that have taken place in America and elsewhere (Anthony 1996, 1990).
Indeed, there is evidence that the “robot” version of brainwashing concept
became almost hegemonic and widely accepted within the general public and
policy makers (Bromley and Breschel 1992; Richardson 1992). And now the
brainwashing concept is being tied to current terrorism threats, as explanations
are sought about why some young people in America and elsewhere are seeking
out participation in violent terrorist groups.
“Brainwashing” in legal systems
The unpopularity of the assumed brainwashing process and the NRM groups
or activities with which it was associated has led to attempts at social control
involving both legal maneuvers and other extra-legal actions such as “depro-
gramming.” As the term “brainwashing” gained popular acceptance in Amer-
ica, legal actors involved in early NRM court cases in the 1960s and 1970s
were willing to accept evidence of “brainwashing” and “mind control” under
the Frye standard for admissibility of scientific evidence even though “general
acceptance” of the concept as an explanatory device was lacking (Anthony
1990, 1999; Anthony and Robbins 1992; Ginsburg and Richardson 1998).2
2. The Frye standard derived from a 1923 cases involving use of an early version of a lie
detector device. The court ruled that novel scientific evidence could not be introduced
in court unless such evidence was generally accepted in relevant disciplines. This was the
rule in American courts for seventy years, until 1993 when a new evidentiary standard was
promulgated by the United States Supreme Court in the Daubert v. Merrell-Dow Phar-
maceuticals. This case required a more rigorous and substantive examination of proffered
scientific evidence. As discussed in Anthony and Robbins (1995) and Ginsburg and Rich-
ardson (1998) “brainwashing” based testimony also could not meet this more rigorous test
that required not only the old general acceptance criterion, but also a demonstration of its

Most judges and attorneys knew as much (or as little) about the scientific
status of brainwashing-based claims as did the general public.3
As the moral panic over “cults” and brainwashing grew and expanded,
brainwashing was increasingly introduced as evidence in both civil and crimi-
nal legal cases (Ginsburg and Richardson 1998; Richardson 1995). However,
government entities within the U.S. encountered difficulty exerting direct
control over the groups, because religious groups are afforded constitutional
protection in the United States. The Free Exercise and Establishment Clauses
of the First Amendment seemingly place limits on governmental entities
directly monitoring religion in America (but see Richardson and Robbins
2010; and Anthony and Robbins 1992).
The lack of overt access to governmental social control in the U.S. led
many toward “self-help” remedies such as deprogramming instead. Accord-
ing to Robbins and Anthony (1979), “brainwashing” became a conceptual
“social weapon” used to justify the use of coercive measures against allegedly
“brainwashed” individuals, including forcible kidnapping and deprogram-
ming. Deprogramming was a process intended to compel NRM members
to return to “normal” society and resocialize NRM members back into their
former lives (Bromley and Richardson 1983). Underpinning that rationale
was the questionable claim that members of NRMs were “brainwashed” into
joining the group and in need of “rescuing,” which served to justify the use
of force involved in deprogrammings. Although these actions often involved
illegal activity, such as kidnapping and holding young, legally of age adults
against their will, government and law enforcement officials often ignored
the actions of the deprogrammers because they shared popular opinion that
NRMs were harmful to individual participants, destructive of families, and
that deprogramming was a family prerogative (Richardson 2000, 2011).
Eventually, those negatively affected by the courts allowing brainwashing
evidence attempted to block its usage in court, and the future of brainwash-
ing evidence became problematic (Anthony 1990, 1996, 1999; Ginsburg
and Richardson 1998). Social and behavioral scientists and some professional
organizations became concerned about the use of this questionable and preju-
dicial evidence in court cases. They attempted to discredit brainwashing-based
falsifiability or testability, and error rate information when the evidence being proffered
was applied to in specific cases.
3. Regrettably, the knowledge of social and behavioral science evidence and scientific evidence in
general is quite low among judges in the United States, as is the ability to discern evidence that
meets scientific criteria (Gatowski, Dobbin, Richardson and Merlino 2001; Dahir, Richardson,
Ginsburg, Gatowski, Dobbin and Merlino 2005).

testimony through the use of amicus briefs, pre-trial hearings on admissibility
of such evidence, and rulings entered on appeal to have brainwashing based
evidence inadmissible (Anthony 1990, 1999; Richardson 1997, 1998a).
One major case, United States v. Fishman, undercut use of brainwashing
evidence in the federal judicial system, which in turn led its being limited in
state courts systems as well. This federal court decision rejected proffered evi-
dence of brainwashing outright after the submission of material from schol-
ars, especially Dick Anthony, criticizing brainwashing theories (Anthony and
Robbins 1992, 1995). The ruling in this case, paired with the limitations on
governmental entities in the U.S. exerting direct control over new religious
groups, made the future of brainwashing evidence problematic, although it
still is proffered occasionally in cases involving religion, as will be shown.
During this same period of time, the legal system ushered in the use of
specialty courts as a means of social control of deviant behavior that aimed to
change such behaviors, but to do so in a “non-punitive” way (Wiener et al.
2010). These courts rely heavily on the medicalization of deviant behaviors
(Conrad and Schneider 1992) with the idea being that it is better to provide
“therapeutic” intervention than criminal sanctions (Davis 2003). This resulted
in courts designed to deal with alcohol and drug addictions, mental illness,
child abuse, domestic violence, divorce and child custody, homelessness, and,
most recently, military veteran’s courts (McMichael 2011). Although brain-
washing may have fallen out of favor for use in legal actions against NRMs
because of the Fishman decision, the concept and related terms are now find-
ing a home in other types of cases.4
The following analyses will show that the concept of brainwashing has dif-
fused within the American justice system. Such evidence is still being intro-
duced in legal cases ranging from rehabilitation and employment practices to
custody cases in family courts. In family courts the concept of Parental Alien-
ation Syndrome (PAS) (Garner 1987, 1992) depends heavily on acceptance
by judges that psychological coercion or “brainwashing” can be used with
children to convince them that one parent’s actions are harmful and should
be rejected. The term also has begun to be employed in mass media coverage
4. It is worth noting that the major proponent of brainwashing theories in NRM legal cases,
Margaret Singer, who testified in over forty such cases, used almost interchangeably the
terms “mind control,” coercive persuasion,” “thought reform,” and “brainwashing” in her
testimony (Anthony 1990). A similar claim can be made about the major brainwashing
promoter in Europe, Jean-Marie Abgrall (Anthony 1999, 425). And Robert Lifton (1999,
342) in his treatment of the grave implications of Aum Shinrikyo’s violence, treats the
terms as synonyms (and also places them in quotes when he uses them).

of why and how radical Islamic movements are attracting young people from
across the western world to join such movements or to take violent actions on
behalf of such causes. The term already has appeared as well in a few criminal
cases brought against participants in radical Islamic movements.
Several scholars who have studied NRMs and/or violence in religious groups
have attempted to bridge the area of NRM studies with that of terrorism
research. Olesen and Richardson (2007) lament the lack of interaction between
scholars in the two fields, and point out that scholars in both fields of study
have moved toward a more contextual and interactionist, agency-oriented social
psychological perspective in addressing why groups are able to recruit people,
and why people choose to participate. This means, among other things, that
researchers in both areas are rejecting psychopathological interpretations of why
individuals join such movements. Participants are not crazy and they are not
“brainwashed.” Instead participants in both types of movements tend to be ide-
alistic, self-motivated, and they are making choices that to them appear rational
and positive for themselves, no matter what others might think of the choices
that are being made. Dawson (2009), another NRM scholar, draws a similar
conclusion is his assessment of research in the two fields of study. He focuses
particularly on how and why violence erupts with some groups in certain situ-
ations, and urges more communication and cooperation between scholars
who research the two areas. Robert Lifton also has examined the confluence
of religion and terrorism, focusing particularly on the Aum Shinrikyo episode
in Japan, noting that for the first time in human history religiously motivated
violence can involve weapons of mass destruction.
Catherine Wessinger (1999, 2000), a religious studies scholar and recog-
nized expert on violence in religious groups, has developed an impressive theo-
retical approach to explaining why violence develops in certain religious and
religiously-oriented groups. Her quite nuanced approach mentions the term
“brainwashing” a number of times, as do contributors to her edited volume
(2000). And in every instance the opinion is the same: the concept “brainwash-
ing” has little utility in understanding why some groups are involved in vio-
lence, and it has been rejected by virtually all scholars studying religious groups
caught up in violent situations. Indeed, Wessinger posits an interactionist view
of violence involving religious groups (see Richardson 2001) that avoids a psy-
chologized and individualized view of violence and instead notes that it is a
result of certain kinds of interactions between groups and external forces.
However, in spite of the strong and near unanimous opinions of scholars in
both camps, in recent years the term “brainwashing” has become an explana-
tory device of choice for many as they seek understanding of why young peo-

ple are joining radical Islamic groups. We will report on the results of some
new research we have done very recently on this new development, but first
will discuss how the term “brainwashing” has spread through other parts of
the legal system in America.
Current research
The term “brainwashing” (or similar terms such as “mind control”) has
become increasingly applied to any situation in which belief change was per-
ceived as coerced, and destructive or deviant behavior supposedly followed.
The term (and synonyms) has spread around the world, as shown by several
scholars (Anthony 1996; Richardson 1996; Shterin and Richardson 2002,
and Richardson and Introvigne 2001). Although the number of legal cases
involving new religions and brainwashing evidence declined in the U.S. after
Fishman, a close examination of recent court records reveals that brainwash-
ing-related evidence is still being applied in a wide range of cases.
Cases involving concepts such as brainwashing and mind control from 1960
to mid-2014 were collected using the search terms “brainwashing” and “mind
control” in the WestLaw and LexisNexis search databases for U.S. cases, and
case lists were cross-referenced to prevent overlap. They were then analyzed to
determine the frequency with which brainwashing was applied to legal cases
(see Table 1), and how brainwashing evidence was applied in each case.
Cases were placed in the following categories only if brainwashing, mind
control, or “cult” membership/formation were pertinent to the case itself.
Any reference to past cases or references to these concepts unrelated to the
specific case at hand were coded as “unrelated.” A cursory examination of the
case type frequencies shows a clear documented increase in the number of
cases involving the concept of brainwashing, even after accounting for the
number of cases in which the search term “brainwashing” appeared in ways
unrelated to the current project. As will be shown, the use of the concept
occurred frequently in specialty courts, particularly family courts handling
custody battles between divorcing spouses. However, the term also appears in
other legal contexts, as will be shown.
Specialty courts
Family/custody (general). These cases (12.4% of total cases) include divorce
suits in which one spouse claims that the other’s membership in a “cult” is
relevant to divorce proceedings. Such claims occur when a parent sues for
custody of their children or claim that one parent/set of grandparents are
unfit to serve as custodians or visit due to cult membership (often these cases

1950– 1960– 1970– 1980– 1990– 2000– 2010– %

Type
1959 1969 1979 1989 1999 2009 2014 (as of 2014)
Specialty Courts
Family/custody — general 4 3 7 13 43 70 6 12.36%
Conservatorship/will contest – 2 1 1 1 1 2 0.49%
Family/custody — PAS – 1 4 9 29 38 36 12.03%
Criminal Courts
Excuse for criminal behavior 1 1 3 11 20 19 20 6.34%
Aggravating evidence – 2 6 30 50 32 11 6.99%
Forced confession 2 5 4 7 5 8 13 3.41%
Mental illness 2 2 1 11 27 49 3 8.46%
Other 9 10 6 23 38 32 4 5.85%
Prison/probation – 3 1 4 15 33 11 7.15%
Civil Courts
Rehabilitation/counseling/
church total
False memories/SRA – – – – 17 6 2 1.30%
“Brainwashing” patient – – – 11 2 12 4 2.60%
Employment/work place – 3 3 4 9 24 2 4.23%
Education 1 2 4 12 8 1 3 0.65%
Book banning/dissemination
5 6 1 – 1 2 – 0.33%
of obscene materials
Defamation 4 2 8 19 39 26 2 4.55%
Immigration cases — other – – – – 1 19 1 3.25%
Immigration cases — Falun
– – – – – 50 2 8.46%
Gong
Government conspiracy – – 1 2 5 1 54 8.94%
MK Ultra/CIA – – 1 4 5 9 - 1.46%
Deprogramming – – 4 6 5 2 1 0.49%
Civil — other 9 6 18 19 8 1 3 0.65%
Related Total 37 48 73 186 328 435 180
Unrelated 17 24 36 93 224 1074 56
Total 54 72 109 279 552 1509 552
Table 1. Both state and federal cases involving “brainwashing,” “cult,” and “mind
control”

involved the LDS [Mormon] church and Jehovah’s Witnesses).
Family/custody (PAS). These cases (12.0% of total cases) include any child
custody cases in which a parent has allegedly “alienated” the child/children
in question, and aligned the child/children in their favor, against the other
parent. The introduction of evidence of parental alienation is hardly a new
concept in the legal system, as divorce and custody cases involving abus-
ers and their victims have dealt with this issue for some time (Meier 2009).
In fact, this phenomenon of alignment of a child against one parent was
first identified by divorce researchers Wallerstein and Kelly (1976, 1980).
Application of the label “parental alienation syndrome,” including use of the
term “brainwashing” while discussing the child or children’s current state of
mind, was widely promoted with a series of publications by Gardner (1987,
1992), based solely on his own experience in his clinical practice. According
to Gardner, roughly 90% of children involved in custody litigation suffered
from the “disorder” of PA. And Gardner definitely ties brainwashing to PAS
as shown here in a response to some critics (Gardner 2004, 614):
It is true that I do focus on the brainwashing parent, but I do not agree that
such focus is ‘overly simplistic.’ The fact is that when there is PAS, the primary
etiological factor is the brainwashing parent. And when there is not brainwash-
ing parent, there is no PAS… This does not mean that all alienated children have
brainwashing parents. What this means is that there is a subcategory of alien-
ated children who do have brainwashing parents.
Critiques of Gardner’s work focused on his lack of empirical basis for his
claims and the circularity of his argument (Meier 2009; Johnston and Kelly
2004; Kelly and Johnston 2001). However, these critiques by legal actors and
researchers alike have not stopped the introduction of PAS into divorce and
custody litigation, as evidenced by the current analysis.
A few cases (just under half a percent) in family courts were typically brought
either by the family of a deceased individual who claimed that the deceased was
“brainwashed” or under “mind control” of another individual or group which
convinced them to leave their property (estate, money, etc.) into the care of the
individual or group rather than family members. A few cases also where brought
by family members of a living relative who they fear is being “brainwashed” to
do the same and who wish to be instated as legal guardians over the estate.
Criminal courts
Brainwashing and mind control related evidence was frequently introduced
in criminal proceedings both by the prosecution and the defense with a num-
ber of different uses.

Excuse for criminal behavior: These cases, which make up roughly 6.3%
of current cases involving brainwashing, included any in which evidence
of “cult” involvement, “brainwashing,” or mind control were introduced as
a possible defense in a criminal trial. For example, in the well-known case
United States v. Fishman, Fishman was tried in federal court for embezzling
money. Fishman’s counsel claimed unsuccessfully that he had operated under
diminished capacity and that a defense of insanity was warranted, as Fishman
had been “brainwashed” by the Church of Scientology to commit the crimes
(Anthony and Robbins 1992).
Aggravating evidence: These cases (7.0% of total cases) included any in
which evidence of “cult” involvement, “brainwashing” or “mind control”
were introduced by the prosecution in a criminal case in an attempt to por-
tray the defendant in a negative light or to establish motive or intent to com-
mit the crime.
Forced confession: These cases (3.4% of total cases) included any in which
the defense claimed that a confession given for a crime was coerced by police
using “brainwashing” techniques on the defendant.
Mental illness: These cases (8.5% of total cases) included any in which “cult”
involvement, “brainwashing,” or mind control was introduced as evidence of
mental defect, warranting an insanity defense (similar to the ‘Excuse for crimi-
nal behavior’ category, but specifically followed by a claim of mental defect).
Criminal (other): These cases (5.9% of total cases) include any in which
“cult” involvement, “brainwashing,” or mind control was introduced as evi-
dence in a criminal trial, and was directly related to the charges, but did not
fall into any of the above categories. These often included claims that the
victim or jury were “brainwashed,” attempts to discredit victim or witness or
shift blame onto imaginary “cult,” and failure to submit to induction of the
armed services.
Civil courts
Brainwashing and mind control evidence also has been introduced in a num-
ber of cases in civil courts, both by plaintiffs and defendants.
Prison/probation: These include any case (7.2% of total cases) in which
inmates were denied the right to practice their religion, most often through
confiscation of materials required for worship (such as candles, books, etc.).
Rehabilitation/counseling/church: These cases (3.9% of total cases) involve
any in which an individual claimed adverse effects as a result of counseling of
any kind, either through rehabilitation, a secular counseling center, or their
membership with a non-mainstream church. They fell into two categories:

False memories/SRA: Former patients sued counselors/therapists for implant-
ing false memories of satanic ritual abuse that led to emotional distress/psy-
chosis (1.3% of total cases).
“Brainwashing” patient/member: Former patients of rehabilitation centers
or counseling and former members of non-mainstream churches claimed
that they had been brainwashed (2.6% of total cases).
Employment/work place: Former or current employees allege that employ-
ers (either individual authority figures or the company itself ) “brainwashes”
employees, or employees are discriminated against based on religious prefer-
ence (mostly toward members of the Church of Jesus Christ of Latter-Day
Saints [LDS] and Jehovah’s witnesses) (4.2% of total cases).
Education: These cases (.7% of total cases) include any in which allegations
of “brainwashing,” “cult activity,” or “mind control” are directly connected to
educational settings, including (but not limited to): teachers “brainwashing”
children, religious discrimination (mostly toward LDS members and Jeho-
vah’s witnesses) in schools, etc.
Book banning/ dissemination of obscene materials: These suits (.3% of total
cases) were brought against individuals or groups involved in the dissemina-
tion materials that promoted obscenity (as in the cases of the “nudist cult”
materials, etc.) or cult beliefs (as in the cases of Jehovah’s Witnesses distribut-
ing their religious material, etc.).
Defamation: This category includes any case (4.6% of total case) in which an
individual or organization sued another for libel for claiming “cult” associa-
tions or that the plaintiff had “brainwashed” or performed “mind control” on
its members/employees.
Immigration cases (Falun Gong). These cases (8.5% of total cases) involve
Chinese citizens seeking asylum from the U.S. government because returning
to China would mean persecution for membership in Falun Gong, declared
by the Chinese government in 1999 as an “evil cult.”
Immigration cases (other): These cases (3.3% of total cases) involve citizens
seeking asylum from the U.S. government to avoid persecution in their home
countries based on religious beliefs (all religions excluding Falun Gong).
Government conspiracy: These cases (8.9% of total cases) included any in
which an individual sued the United States Government, the President of the
United States, or any celebrity (or any combination of the three) for allegedly
implanting mind control devices, controlling behavior through wave lengths,
plotting to hurt them or others, etc.
MK Ultra/CIA: These suits (1.5% of total cases) are brought by plaintiffs
allegedly involved in alleged trials by the CIA known as Project MK-Ultra in

which human subjects were experimented on with “mind control” through
the use of hallucinogenic drugs.
Deprogramming: These suits (.5% of total cases) were brought against
“deprogrammers,” individuals who specialized in reversing the “brainwash-
ing” that allegedly took place in cult groups in an effort to revert the cult
member to their original state of mind. Such cases were typically brought by
the group member and involved allegations of kidnapping.
Civil (other): These cases (.7% of total cases) include any in which “cult”
involvement, “brainwashing” or mind control is alleged in a civil suit, and is
directly related to the charges but did not fall into any of the above categories.
Some examples of these cases include (but are not limited to):
a. City denied gay and lesbian group right to march in parade — compared
group to a religious cult
b. City denied religious group booth at state fair
c. Ban on placing campaign materials outside voting location to avoid “brain-
washing” voters
d. City ordinance bans animal sacrifices — group brings suit on First Amend-
ment violation
e. Deemed too dangerous to sell registry of licensed drivers to religious group
f. City stopped residence from being used for worship amid neighborhood
“cult” fears
g. Revoked probation for teaching as leader of religious group
h. Alienation of daughter’s affection by religious group
i. City clerk would not allow member of religious group a marriage ceremony
without pants — group member sued for First Amendment violation
j. Church fights revocation of tax-exempt status/church sues for tax-exempt status
k. Jehovah’s witness groups sued in order to distribute literature
l. Chiropractic-related cases
“Brainwashing” and terrorism

We recently have done additional searches of international mass media to see
if the terms terrorism and “brainwashing” are being linked. If this is occur-
ring, then this will be analogous to what happened concerning NRMs, where
the media played a major role in disseminating the brainwashing” myth
about NRM participation. It turns out that indeed, this linkage is occurring
and with increasing frequency. Using the Lexis-Nexus Academic database,
we have found 196 instances where the terms are linked in mass media from
around the world, and the frequency of such linkage is increasing. We found
one such story in 1985, and a few in the early 1990s, but many more in
recent years. And, interestingly, the majority of media coverage linking the

two terms is not occurring in America, but is to be found in media outlets
from around the world.5
We also have done a search using the Lexis data base of cases, both federal
and state, and have found a few cases in recent years where the term brain-
washing has been used in cases involving terrorism charges. More research
must be done to determine how “brainwashing” is being used in the cases,
and if this occurs with increasing frequency.
Discussion and conclusions
It is quite remarkable that a term first appearing in the English language
in the 1950s as part of an ideological battle with Chinese communism has
become so pervasive that its use in everyday parlance and in the legal system
has become almost commonplace. Why and how diffusion of such a scientifi-
cally questionable concept in America and elsewhere warrants further study
by social and behavioral scientists, as well as legal scholars.
The previous discussion clearly shows that although the use of brainwash-
ing in court cases involving new religious movements since the Fishman deci-
sion has declined in the U.S., the concept of brainwashing is increasingly
being introduced in a number of other types of court cases, including family
court cases involving divorce or child custody and a few recent cases involv-
ing terrorism accusations. The concept of brainwashing which has been used
in developing psychological syndromes such as “destructive cult syndrome”
(Richardson 1992; Richardson and Stewart 2004) has more recently served
to underpin the controversial concept of “Parental Alienation Syndrome,”
(Meier 2009; Gardner 1987, 1992, 2004) and also has served as a ready, even
if naïve, explanation of why and how young people are joining radical Islamic
movements or effecting violence in the name of this version of Islam.
A theoretical framework that may explain the diffusion of “brainwashing”
evidence in the legal system in the United States from “cult cases” to other
areas of the law was offered by Richardson and Ginsburg (1996) and then
was expanded upon in Gatowski, Dobbin, Richardson, and Ginsburg (1997)
to help explain the wide diffusion of “battered spouse syndrome” within legal
systems in western societies. This theoretical approach posits a number of
mechanisms that contribute to the diffusion of behavioral science evidence
in a legal system, including: (1) credible sources for dissemination; (2) the
culture of the legal system; (3) legal actors’ attitudes toward the use of sci-
entific evidence; and (4) political support for the use of the evidence, each
5. We will be doing a more thorough analysis of the media data set and the one involving
legal cases, but are reporting preliminary impressions only here.

of which will be discussed below. Dobbin and Gatowski’s (1999) research
on “rape trauma syndrome” is also useful, as it presents a “social produc-
tion of evidence” model based on the work of Cooney (1995). Dobbin and
Gatowski develop concepts such as “evidence entrepreneur,” “evidence indus-
try,” and “product champions” from Cooney’s work, and illustrate them with
the diffusion of rape trauma syndrome. All of these terms and the general
approach seem applicable to what has happened with the dissemination of
“brainwashing” as an explanation in the NRM area (see Shupe and Bromley
1980; Bromley and Richardson 1983), and it would be useful to examine the
applicability of the terms to the spread of “brainwashing in the terrorism area
as well. However, herein we will only apply the theorizing of Gatawski et al.
(1997) in more detail.
Credible dissemination sources provide a knowledge base from which legal
actors can access information about how the “scientific” evidence has been
used in the past. Gatowski et al. (1997) name several possible credible dis-
semination sources including U.S. case law and expert witnesses. Accord-
ing to Richardson (1991), civil cases against NRMs have seen considerable
success employing “brainwashing” evidence in cases, some of which have
resulted in multi-million dollar verdicts, effectively developing a path for
future successful uses of the concept in cases involving discontented former
members of NRMs (or their families). In many of these early cases alleging
“brainwashing,” a well-known clinical psychologist Margaret Singer, PhD.,
testified supporting the scientific merit behind theories of “brainwashing.”
Singer’s efforts to promote brainwashing explanations of NRM participation
initially met with some success, likely encouraging diffusion and lending fur-
ther credence to the idea that “brainwashing” should be considered valid
science, even while ignoring a vast amount of research disproving her posi-
tion (Anthony 1990; 1996; Richardson 1991). (However, recall that it was
Singer’s testimony that was rejected in the Fishman case referred to earlier.)
Secondly, the culture of the legal system, according to Gatowski et al. (1997),
is dictated by a number of considerations, including rules of evidence and
admissibility standards, and formal and informal education of legal profes-
sionals. Higher standards for scientific sophistication in admissibility of evi-
dence are only possible when legal professionals obtain training in scientific
research methods, and are therefore able to evaluate the scientific merit of the
evidence (Gatowski et al. 1997). Admission of such evidence by legal decision
makers untrained in scientific methods contributes to its perceived legitimacy
and to its diffusion in the legal system. In the case of brainwashing-based
testimony, it seems clear that judges and juries initially accepting such tes-

timony were caught up in the moral panic that surrounded NRMS for a
time in America and elsewhere (see Richardson 2000). This led to a flexible
application of usual criteria for the admission of evidence in a number of
legal actions against NRMs.
Thirdly, decision-making by legal actors about scientific evidence profoundly
influences operations within the legal system. Attorneys may advocate for
the admission of evidence in a particular case based on its scientific merit
(Gatowski et al. 1997), with the assumption that evidence claimed to be
“scientific” appears more credible than any non-scientific evidence (Sherif
and Sherif 1967). Judges may agree with this logic, and accept such evi-
dence without understanding its lack of scientific credibility (see Gatowski et
al. 2001). As previously mentioned, although “brainwashing” evidence has
failed to meet the formal requirements for admissibility as scientific evidence
(Anthony 1990, 1996; Anthony and Robbins 1992; Richardson 1991, 1993,
1994, 1996; Richardson et al. 1995; Ginsburg and Richardson 1998), it
seems that some legal actors persist, and “brainwashing” evidence continues
to be introduced in various kinds of cases, even as its use in so-called “cult/
brainwashing” cases has diminished considerably.
Lastly, some researchers also have suggested that political and popular opin-
ion influences which evidence is admitted (Ginsburg, and Richardson 1998;
Richardson 2000; Shterin and Richardson 2000), which seemed the case
with proffered brainwashing evidence. As stated previously, U.S. government
officials were limited in the ability to exert control over NRM groups initially
because of constitutional protection afforded religious groups in the U.S. In
the 1990s in the United States, “brainwashing” evidence was admitted in
courts less and less as social scientists and legal professionals began to doubt
the credibility of the evidence (Anthony 1990, 1996; Ginsburg and Richard-
son 1998).
However, as demonstrated in our data, popular acceptance of the concept,
coupled with its obvious utility as an “account” of otherwise controversial
behaviors, resulted in such evidence being introduced and accepted in spe-
cialty courts, including family and juvenile courts and, more recently, in cases
involving terrorism. The proliferation of specialty courts designed to control
deviance outside the usual criminal justice system has allowed the concept of
brainwashing (and its synonyms) to be used in a variety of court cases, and it
also is appearing in cases dealing with terrorism.
The very notion that someone could be manipulated into performing devi-
ant acts without the use the physical coercion presents a unique challenge
for the any legal system built on a foundation of individual responsibility.

However, with reference to specialty courts, this becomes less of a challenge
for the system when the court itself is designed to identify, define, and control
deviant behavior in a “therapeutic” manner (Davis 2003).
It is important to note, as the idea of brainwashing diffuses into civil ther-
apeutic courts, the standard of evidence is lower than in civil or criminal
cases, and the court is oriented toward psychological explanations for devi-
ance, making it easier for questionable concepts like “brainwashing” to be
accepted. As long as legal actors (judges and juries) are willing to accept psy-
chotechnology such as “brainwashing” that cannot be directly falsified (Gins-
burg and Richardson, 1998), legal systems will continue to be forced to deal
with brainwashing-based claims in the future.
The more recent usage of brainwashing as an explanatory device in a few
terrorism cases and in a number of media discussions of terrorism raises sev-
eral types of problems. As an explanatory device, “brainwashing” is as want-
ing with young converts to terrorism as it has been with NRM participants
(Dawson 2009). However, if a “brainwashing” explanation is accepted about
why people join radical movements, then will it also be accepted as a defense
when some of those recruits are charged criminally for actions they have
taken? This has not occurred in NRM cases (recall that Fishman was a crimi-
nal case), but what might happen in this new arena? Another issue that rises
from uses of “brainwashing” in terrorism situations concerns the use of the
internet. While there was some attention to using the internet for recruit-
ment in the latter days of the moral panic about NRMs, the internet has now
become a major issue with recruitment to terrorism. Claims that one can be
brainwashed via the internet seem far-fetched, but are now surfacing in the
debate about western young people going in fairly large numbers to fight in
Syria and other locations. This claim raises many issues that need attention
from scholars of various disciplines.
Proffering of brainwashing-related terms in legal systems as explanations of
behavior should continue to be studied, building on and expanding earlier
comparative work by scholars who have studied how widely this relatively
new concept has been diffused within society and the legal system. The con-
cept seems quite resilient and adaptable to new situations. Policymakers and
scholars need to attend to recent developments, and be prepared for other
novel uses of what has become a very convenient term to use when develop-
ing explanations of activities that are difficult to understand and controver-
sial. Indeed, if the term remains viable it may even find new applications to
future unpopular and controversial NRMs.

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International Journal for the Study of New Religions 6.

Jenny Reichert,1 James T. Richardson,2 and Rebecca Thomas2

Heidelberg University, 2University of Nevada, Reno

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