R E G U L A R A R T I C L E

Pathological Lying Revisited

Charles C. Dike, MD, MRCPsych, MPH, Madelon Baranoski, PhD, and
Ezra E. H. Griffith, MD

Although pathological lying was first described in the medical literature over 100 years ago, it remains a poorly
understood concept. Psychiatrists continue to grapple with the full ramifications of the condition, even though
interest specifically in pathological lying seems to have waned in recent times. The impact of pathological lying
deserves critical attention from forensic psychiatrists because of the implications that untruths have in a legal
context. In this article, the authors review the considerable vagueness and confusion that has surrounded this
concept and examine the extent to which a person can control lying behavior and the related question of whether
pathological liars have responsibility for their actions. While providing a structured framework for considering
pathological lying in the forensic context, the authors conclude that further systematic research is needed to
resolve the questions raised in this article.

J Am Acad Psychiatry Law 33:342–9, 2005

In August 2001, the State of California Commission 1, p 10). The expert further testified that pseudologia
on Judicial Performance ordered the removal from fantastica is treatable with therapy and did not render
office of Judge Patrick Couwenberg for making mis- Judge Couwenberg unfit for judicial service. The ba-
representations to become a judge, continuing to sis for the conclusions regarding treatment and fit-
make misrepresentations while a judge, and deliber- ness for judicial service was not stated in the reference
ately providing false information to the Commission article and therefore is not available for review.
in the course of its investigation.1 The judge had lied Cases like Judge Couwenberg’s continue to
at various times to judges, attorneys, a newspaper emerge from time to time. Recent media articles
reporter, and the Commission on Judicial Perfor- chronicling the lying behavior of prominent men
mance. He told the Commission, under oath, that he such as Joseph J. Ellis,2 a Pulitzer Prize winning his-
had participated in covert CIA operations in South- torian and professor of history at Mount Holyoke
east Asia and Africa and that he had a master’s degree College; Jeffery Archer,3 member of the House of
in psychology when, in reality, he had never been in Lords of England; and Sir Laurens Van der Post,4
the CIA nor did he have a degree in psychology. He former spiritual adviser to Prince Charles and godfa-
had committed many other misrepresentations, in- ther to Prince William, have generated significant
cluding stating that he had received a Purple Heart interest. A former student of Professor Ellis, upon
for injuries sustained in Vietnam and dramatically learning of his mentor’s lies was quoted as saying,
reporting that shrapnel was still lodged in his groin. “He seemed so genuine. Perhaps it was a fantasy he
In reality, he was never in Vietnam during the war.1 came to believe himself ” (Ref. 5, p A12). This obser-
A psychiatrist expert witness testifying before a vation raised important questions: did the just-
panel of three judges sitting as special masters inves- named individuals consciously and willfully engage
tigating Judge Couwenberg concluded that the judge in spewing their lies or were they unable to control
was suffering from pseudologia fantastica which he their lying?
described as “story telling that often has sort of a The concept of pathological lying, in which an
matrix of fantasy interwoven with some facts” (Ref. individual repeatedly and apparently compulsively
tells false stories, is not new to psychiatry. Numerous
Dr. Dike and Dr. Baranoski are Assistant Clinical Professors, Law and articles were written on it in the first half of the 20th
Psychiatry Division, Department of Psychiatry, and Dr. Griffith is
Professor of Psychiatry and African-American Studies, Yale University century. However, interest in it waned drastically, to
School of Medicine, New Haven, CT. Address correspondence to: the extent that in recent years, it has received very
Charles C. Dike, MD, MRCPsych, MPH, Connecticut Medical
Health Center, Law and Psychiatry Division, 34 Park Street, New little mention. Yet, the relatively modest light shed
Haven, CT 06519. E-mail: [email protected] on pathological lying in recent psychiatric literature

342 The Journal of the American Academy of Psychiatry and the Law
 Dike, Baranoski, and Griffith

may not reflect its true prevalence in the pathology tage does not appear to be the primary motivating
encountered routinely by clinical psychiatrists. force but the lying is an end in itself; an inner dy-
Rather, it may be that psychiatrists simply know little namic rather than an external reason drives the lies,
about the subject and have difficulty recognizing the but when an external reason is suspected, the lies are
phenomenon. far in excess of the suspected external reason; the lies
Lies have been written about and classified for are often woven into complex narratives.
centuries. However, as noted by Healy and Healy,6 it We shall define pathological lying as Healy and
was a German physician (Dr. Delbruck) who first Healy8 did, but without the quagmire of etiology.
clearly described the concept of pathological lying Pathological lying is falsification entirely dispropor-
after an extensive examination of lies told by five of tionate to any discernible end in view, may be exten-
his patients. He concluded that these lies were so sive and very complicated, and may manifest over a
abnormal and out of proportion that they deserved a period of years or even a lifetime.
special category, which he described as pseudologia In this article, we revisit the concept of patholog-
phantastica, terminology that is used interchangeably ical lying and explore how it has been discussed in
with pseudologia fantastica, which may be an Ameri- psychiatric literature. We intend to review the histor-
canized spelling. Pathological lying, pseudologia fan- ical development of the concept and explore its cur-
tastica, mythomania and morbid lying are generally rent status in modern-day psychiatry. We want to
used interchangeably, although it remains debatable establish the similarities and differences between
whether they all describe the same phenomenon. In- pathological lying and other more popular psychiat-
deed, Bursten’s7 description of Manipulative Person- ric syndromes, such as confabulation, delusional
ality shows characteristics similar to those of patho- thinking, factitious disorder, and malingering. Fi-
logical lying. Nevertheless, for the purpose of this nally, we pay attention to the significance of the con-
article, we make no distinction among the terms just cept in forensic psychiatry and the approach to the
described. In addition, we confine our discussion to forensic assessment of pathological lying.
the narrow phenomenon of pathological lying and
do not consider the broader concept of lying. The Historical Evolution of Pathological Lying
latter subject has been the object of considerable Pathological lying has been compared with the
discussion. “pseudolying” observed in children. Despite their
Many articles have variously defined pseudologia obvious comparability, it is important to draw a dis-
fantastica, but a commonly quoted definition is that tinction between the “fantasy” lying observed in chil-
put forth by Healy and Healy8 who described it as dren and pathological lying. Children’s use of fantasy
“falsification entirely disproportionate to any dis- to deny reality is said to be an important aspect of
cernible end in view, may be extensive and very com- self-development and self-protection, but when this
plicated, manifesting over a period of years or even a persists into adulthood, it becomes pathological. It
lifetime, in the absence of definite insanity, feeble- has been proposed that the pathological liar’s ego is
mindedness or epilepsy” (Ref. 8, p 1). While this is a fixated at the childhood level.10
very comprehensive definition, it raises the question Eminent psychiatrists, such as Schneider,11
of whether definite insanity, feeblemindedness, or Bleuler,12 Jaspers,13 and Fish14 have all wondered if
epilepsy must be absent for lying to be considered the pathological liar recognizes his or her story as false
pathological. or believes it is real. Essential notions in much of the
Selling disagreed. He believed that “obvious men- literature are the basis of the lying and the extent to
tal disease, particularly a diagnosable psychopathic which the pathological lying reflects impairment in
personality of some type” (Ref. 9, p 336) was respon- reality testing. A brief review of past characterizations
sible for pseudologia fantastica. of pathological lying—published by Healy and
While no consensus definition for pathological ly- Healy,8 who translated the early work that was orig-
ing currently exists in the literature, the identified inally published in German and summarized it in
functional elements of the phenomenon are: the re- their landmark text published in 1926 —shows a
peated utterance of untruths; the lies are often re- split between those who believe possible impairment
peated over a period of years, with the lies eventually in reality testing is an important consideration and
becoming a lifestyle; material reward or social advan- those who believe pathological lying is a willful act.

Volume 33, Number 3, 2005 343

 Pathological Lying

Supporters of possible impaired reality testing ob- testing in pseudologia fantastica is the proposition
serve that in the final evolution of the pathological that pseudologues usually have sound judgment in
lie, it cannot be differentiated from a delusion be- other matters, an observation that makes it difficult
cause, to the liar, it has the worth of a real experi- to prove that the pseudologue does not know that
ence.15 The lie ultimately wins power over the patho- what he or she is doing is wrong.
logical liar, so that mastery of his or her own lies is In their work involving pathological liars, Healy
lost. The new “I” supposedly overwhelms the normal and Healy8 observed that utterance of lies comes just
“I” who now appears only at intervals, a condition as quickly and naturally as speaking truth comes to
that has been referred to as systematized delirium.16 other people. They noted that even really insane in-
Consciousness of the real situation was said to be dividuals are not immune to pathological lying; some
clouded in the minds of the pathological liar, and the may tell tales that they recognize to be untrue. This
lies were described as impulsive and unplanned, observation further highlights the controversy about
“seizing” the liar suddenly.17 Pseudologues (patho- whether the pathological liar maintains contact with
logical liars) were therefore not seen as liars in the reality. In the opinion of Healy and Healy, patholog-
true sense, despite the falsehood of their statements, ical lying is very rarely a symptom by itself, as there is
because the verbalizations were not believed to be a tendency for the lying to be embedded in other
consciously engendered, nor the goal consciously forms of misrepresentation. The pathological liar gets
recognized. himself/herself in a tight spot by lying and then tells
Further support for possible impaired reality test- more lies to extricate himself/herself. After a while, the
ing in pathological lying was the observation that the only way out may be to run away to a different location.
lies were more elaborate than ordinary lies and left In summary, the historical review provides some
the grounds of reality more readily. The proposal elements that may be said to characterize the patho-
that pathological lying is a “wish psychosis” was logical liar or at least create a general impression of
based on the observation that pathological liars saw what constitutes pathological lying. Pathological li-
their lies as reality and believed them.18 ars can believe their lies to the extent that, at least to
Opponents of impaired reality testing in patho- others, the belief may appear to be delusional; they
logical lying noted that when the pathological liar’s generally have sound judgment in other matters; it is
attention was energetically drawn to his lies, he could questionable whether pathological lying is always a
be brought to at least a partial recognition of their conscious act and whether pathological liars always
falseness, but when left to himself, he did not exert have control over their lies; an external reason for
his attention in that direction.19 This observation lying (such as financial gain) often appears absent
suggested a degree of willfulness. Pseudologia fantas- and the internal or psychological purpose for lying is
tica was therefore described as a fantasy lie, a day- often unclear; the lies in pathological lying are often
dream communicated as reality, in which the lie can unplanned and rather impulsive; the pathological liar
be a gratification in itself, for pleasure only and not may become a prisoner of his or her lies; the desired
for any other obvious gain.20 It was described as an personality of the pathological liar may overwhelm
intermediary phase between psychic health and neu- the actual one; pathological lying may sometimes be
rosis.20 The notion of “double consciousness,” in associated with criminal behavior; the pathological
which two forms of life run side by side, the actual liar may acknowledge, at least in part, the falseness of
and the desired, and the desired becomes preponder- the tales when energetically challenged; and, in
ant and decisive, has been proposed as the mecha- pathological lying, telling lies may often seem to be
nism underlying pathological lying.21 It has also been an end in itself. However, it is evident that no single
suggested that the mental processes similar to those descriptive tableau of a pathological liar settles all the
forming the basis of the impulse to literary creation nosological and etiological questions raised by the
in normal people is the foundation of the morbid phenomenon of pathological lying.
romances and fantasies of those with pseudologia fan-
tastica.22 The impulse that forces the fabrication of Some Psychiatric Conditions and
stories is supposedly bound up with the desire to play Pathological Lying
the role of the person depicted; fiction and real life Psychiatric conditions that have been traditionally
are not separated. Further support for intact reality associated with deception in one form or another

344 The Journal of the American Academy of Psychiatry and the Law
 Dike, Baranoski, and Griffith

include Malingering, Confabulation, Ganser’s Syn- Factitious Disorder

drome, Factitious Disorder, Borderline Personality In Factitious Disorder, the intentional production
Disorder, and Antisocial Personality Disorder. Lying of symptoms (psychological or physical), often
may also occur in Histrionic and Narcissistic Person- through false means, is solely for the purpose of as-
ality Disorders. A brief description of these condi- suming the role of a sick person. The pathological liar
tions will be offered for the purpose of comparing does not want to appear sick. DSM-IV-TR recog-
them with pathological lying. Although delusion is nizes pseudologia fantastica as a common feature of
not traditionally associated with intentional decep- Factitious Disorder, but one that is not essential for
tion, it has been included to highlight the difficulty the diagnosis. Although Munchausen’s syndrome
of referring to pathological lying as delusional. comes under this diagnosis, the stories of Baron Von
Malingering Munchausen (1720 –1791), a German calvary offi-
cer after whom the syndrome was named by Asher,24
The DSM-IV-TR defines Malingering as the in- as reported by Rudolf Respe in 1785,25 were quite
tentional production of false or grossly exaggerated
fantastic and dramatic and were not told for the pur-
physical or psychological symptoms, motivated by
pose of his assuming the sick person’s role, a crucial
external incentives such as obtaining financial com-
element in Factitious Disorder.
pensation or illicit drugs and avoiding work, military
service, or criminal prosecution. While the purpose Borderline Personality Disorder
of lying is clear in Malingering, it is often unclear in
Pathological lying is not uncommon in patients
pathological lying. In the rare instances when there
with Borderline Personality Disorder.26 Indeed, the
appears to be an external incentive for pathological
core characteristics of the latter disorder foster falsi-
lying, the lies are often so grossly out of proportion to
fications. These patients often lack a consistent self-
the perceived gain that they appear ridiculous. Fur-
identity and hold contradictory views of themselves
ther, some have proposed that the lie in pathological
that alternate frequently. They are prone to loose
lying is not altogether a conscious (or intentional) act
thinking in unstructured situations and may suffer
even when it starts off initially as one.10
transient loss of reality testing. Such distortions of
Confabulation reality complicated by a lack of impulse control and
Confabulation describes falsifications of memory the defense mechanisms of primitive denial, idealiza-
occurring in clear consciousness in association with tion, and devaluation are fertile grounds for patho-
organically derived amnesia. The patient attempts to logical lying.
cover exposed memory gaps with the confabulated Antisocial Personality Disorder
materials. In pathological lying, there is no organi-
cally derived amnesia. In addition, the pattern of Symptoms of this disorder listed in the DSM-IV-
memory impairment in Confabulation is character- TR include deceitfulness and repeated lying for per-
istic, mainly affecting recent memory, in the pres- sonal profit or pleasure. Although it is debatable
ence of intact immediate memory and attention and whether individuals with Antisocial Personality Dis-
concentration. Confabulation occurs in Substance- order lie repeatedly and consistently for internal sat-
Induced Persisting Amnestic Disorder (Wernicke- isfaction alone, given their predominant picture of
Korsakoff’s syndrome), Anton’s syndrome (cortical lying for personal profit, there is evidence that
blindness), and anosognosia. they do.27 The pathological egocentricity character-
istic of this condition may, however, be a key to
Ganser’s Syndrome development of pathological lying in these individu-
The lie in Ganser’s syndrome is limited to approx- als. Although pathological lying may theoretically
imate answers, rather than the elaborate fantasies in occur in Antisocial Personality Disorder, pathologi-
pathological lying. In addition, Ganser’s syndrome is cal liars do not often have disordered antisocial
associated with other features that do not character- personalities.
ize pathological lying: clouding of consciousness
with subsequent amnesia regarding the episode, Histrionic and Narcissistic Personality Disorders
prominent hallucinations, and sensory changes of a Histrionic Personality Disorder is characterized by
hysterical kind.23 dramatic and attention-seeking behavior. These in-

Volume 33, Number 3, 2005 345

 Pathological Lying

dividuals frequently lie to attract attention and in them but media descriptions suggest that their lies
severe cases, the lies may be so frequent as to resemble were not driven by a primary major psychiatric dis-
pseudologia fantastica. Their superficial and dramatic order. Indeed, the psychiatrist who examined Judge
character and constant attention-seeking behavior Couwenberg concluded that he did not have a major
often point to a diagnosis of Histrionic Personality psychiatric disorder. Going back into history, there is
Disorder. no evidence that Baron Von Munchausen had a psy-
Individuals with Narcissistic Personality Disorder chiatric disorder; and, although Munchausen’s syn-
may tell ego-boosting tales to obtain constant ap- drome was named after him, as far as we are aware, it
proval from others. In this condition, lies are mainly was based solely on his pathological lies.
told for the reason of self-aggrandizement, which is Cleckley28 also described the case of a successful
often obvious to the audience. and respected man with a doctorate in physics, whose
stories were filled with exaggerations and falsifica-
Delusions tions, sometimes conscious or half conscious. He
These are false beliefs that are strongly held despite noted that the man was not a psychopath or insane,
incontrovertible evidence to the contrary and that are but he had the attributes of pseudologia fantastica.
generally not shared by others in the individual’s cul- These ego-boosting lies, harmless as they may seem
tural context. Unlike the delusional person, when initially, may lead to serious difficulties for the liar
strongly presented with clear evidence contrary to the when discovered. These examples, though centuries
lies told, the pathological liar may acknowledge, at apart, suggest that pathological lying may occur in
least in part, the falsehood of his or her stories or the absence of another diagnosable major psychiatric
more often, change stories. Although controversial, it disorder.
is worth noting that some have suggested that patho- Also of note is the description of “pseudology à
logical liars may believe their lies to such an extent deux” (Ref. 20, p 383) in the literature, a diagnosis
that the beliefs appear delusional. akin to folie à deux but different in that pseudology
In summary, of the conditions discussed, only rather than delusions are shared.20 Indeed, another
Factitious Disorder, Borderline Personality Disor- article suggested that the primary diagnosis in the
der, Antisocial Personality Disorder, Histrionic Per- dominant partner in this variant of folie à deux is
sonality Disorder, and possibly Narcissistic Person- pathological lying, rather than psychosis,29—a fur-
ality Disorder have an association with pathological ther indication that pathological lying may exist as its
lying. own primary diagnostic entity.

Pathological Lying as a Diagnosis Discussion

While there is no doubt that pathological lying as
a symptom may occur in Factitious Disorder and Clinical Questions
Borderline Personality Disorder, it is less clear Despite the fact that lying is common, it is not
whether it can stand on its own and occur indepen- clear why some individuals become pathological li-
dent of a known psychiatric disorder. Healy and ars, whether it is a mental disorder, and if so, whether
Healy8 suggested that a clear distinction should be it is treatable. Although pathological lying was de-
made between those who lie pathologically as a direct fined in the scientific literature over 100 years ago, it
complication of a psychiatric disorder (secondary has remained poorly researched and its significance
pathological liars, in our opinion), and pathological to the practice of psychiatry largely unclear. Indeed,
liars who do not demonstrate symptoms of a clearly its only mention in the DSM-IV is in association
defined psychiatric disorder (primary pathological li- with Factitious Disorder, but a review of the litera-
ars). In fact, Healy and Healy argued that true patho- ture reveals a subgroup of individuals who exhibited
logical lying should be independent of a primary ma- pathological lying but without evidence of Factitious
jor psychiatric disorder. Both Judge Couwenberg Disorder or any other overt psychiatric disorder.
and Professor Ellis repeatedly told false tales about Although many of these individuals may not have
their exploits, while at the same time pursuing high- cause to seek treatment and may indeed continue to
level professions and contributing to society. We lead highly successful and productive lives, it is not
have not had the privilege of examining either of uncommon for their lying to cause them hardship

346 The Journal of the American Academy of Psychiatry and the Law
 Dike, Baranoski, and Griffith

through clashes with the law or other authorities, ing the development of psychotropic medications,
with resultant adverse consequences. The conse- and as a result, the treatment modality discussed con-
quence for Judge Couwenberg was removal from the sisted mainly of psychotherapy. Even so, the effec-
bench. Judge Couwenberg’s expert witness conceded tiveness of psychotherapy in the treatment of patho-
that although the judge was suffering from pseudolo- logical lying has not been systematically studied. The
gia fantastica, he did not have a DSM-IV diagnosable recent report that up to 40 percent of cases of pseudo-
major psychiatric disorder. He noted, however, that logia fantastica have a history of central nervous sys-
pseudologia fantastica is treatable with therapy and tem abnormalities,30 and the finding of right
did not render Judge Couwenberg unfit for judicial hemithalamic dysfunction by single photon emission
service. Although evidence for this latter clarification computed tomography (SPECT) in a case of patho-
was not available for review, it is important because logical lying,31 suggest a possible role for pharmaco-
for pathological lying to be a desired defense strategy, therapy or other interventions. Research in these ar-
it must be identified as an illness for which one could eas could therefore fruitfully include the use of
be treated and recover fully. Otherwise, the label radioimaging and other studies for diagnosis and a
could be quite damaging to one’s reputation and systematic study of the effectiveness of pharmaco-
credibility. therapy, psychotherapy, or the two in combination.
Pathological lying has been defined in various
ways, and the core symptoms, possible etiological Forensic Implications
factors, and the effect on the individual’s level of When the lies of pathological liars lead directly to
functioning are unclear. Further, it is unknown a clash with the judicial system or with an adminis-
whether pathological lying exists across cultures, trative structure, psychiatrists may be asked to give
whether there are different subtypes of the phenom- advice about the nature of pathological lying. Un-
enon, and whether pathological liars present enough truths are of particular import in forensic assessments
predominant, consistent, and stable symptoms or and present the expert with the challenge of sorting
symptom clusters to delineate clearly a clinical entity through the applicable differential diagnoses that
fit for individual classification in the DSM. System- may encompass pathological lying in a particular
atic collection of data will help not only in clarifying case. We certainly recommend that psychiatrists
these conundrums, but also in determining whether complete a thorough clinical evaluation of these in-
pathological lying is always only a symptom, a syn- dividuals and obtain an extensive longitudinal his-
drome, or a diagnosis. tory of the lying. Obtaining collateral information
We anticipate the criticism that pathological lying from relatives, employers, and other relevant associ-
is merely a behavioral symptom and not a diagnosis. ates would be particularly helpful, as would be a clear
Such a conclusion may, of course, be ultimately cor- understanding of the individual’s past legal entangle-
rect. However, we maintain that at present we lack ments. Attention should also be paid to clarifying
the clinical evidence to draw a conclusion one way or external and internal objectives of the liar. We expect
the other. the evaluation to be better structured if the psychia-
Alternatively, if it cannot be considered a clinical trist recalls the diagnostic entities potentially associ-
entity in its own right, where should pathological ated or confused with pathological lying. Psycholog-
lying be placed under currently existing psychiatric ical testing may also be helpful in establishing
disorders in the DSM? For example, does it meet the whether a psychotic disorder or malingering is
criteria for an Impulse Control Disorder, given the present, or whether the lying is couched in particular
impulsive nature of the lies, or should it simply be personality traits. There is no specific psychological
associated with one or several of the personality dis- test currently available for the detection of patholog-
orders? Obsessive Compulsive Disorder should also ical lying.
be considered, given the notion held by some that We wonder about the frequency of pathological
pathological liars feel compelled to repeat their men- lying in forensic psychiatry settings, and we expect
dacious acts. that in these contexts a clearer definition is crucial.
The options available for treating pathological ly- Psychiatrists have expressed differing opinions on
ing are also poorly researched. Scientific interest in substantive questions about pathological liars: Do
pathological lying was prominent in the era preced- they recognize their stories as false or believe them to

Volume 33, Number 3, 2005 347

 Pathological Lying

be real? To the extent that they believe them as real- consistent story and to bring relevant information to
ity, is there a loss of reality testing? The answers to the attorney’s attention is likely to confuse the attor-
these questions may have implications for the arena ney and impair the collaborative relationship be-
of forensic psychiatry practice. One relevant concern tween the defendant and his attorney.
would be whether an individual is considered re- The questions raised herein create a challenge for
sponsible for any acts associated with pathological the forensic expert, both in formulating and in inter-
lying. Would it be feasible in some cases to assert preting the findings to the court, jury, insurance
that the lying was uncontrollable? We realize that company, or peers. Although consensus on the con-
pathological lying as a defense does not reach the cept of pathological lying is a long way off, the foren-
threshold of insanity in most jurisdictions and we are sic expert still needs a strategy for assessing the con-
certainly not advocating that it should. We believe, nection between pathological lying and the forensic
however, that when the behavior is properly framed problem at hand. When pathological liars get into
for the prosecutors, the defendants may get some trouble with the law or some other administrative
consideration. entity, forensic examiners need to determine whether
A complicating factor in making assertions that to make no recommendations or to argue for exten-
pathological lying is uncontrollable is the observa- uating circumstances. We think that with the infor-
tion that it may sometimes coexist with ordinary lies. mation provided herein, forensic psychiatrists may in
Any evidence of lying for self-benefit is likely to con- certain cases be able to help attorneys frame an argu-
fuse the picture, even if the individual mostly tells ment that may or may not ultimately be exculpatory,
pathological lies. Judge Couwenberg’s misrepresen- but that justifiably presents their clients in a more
tations of his educational qualifications were seen by understandable way to the relevant authorities.
the commission as examples of lying for direct pro-
motion of his self-interest, and even though some of References
his lies were not so easily explicable, he could not 1. State of California, Before the Commission on Judicial Per-
shake off the impression that his lies were for obvious formance: Decision and order removing Judge Couwenberg
gain. Another complicating factor is the observation from office, August 15, 2001. Available at http://cjp.ca.gov/
CN%20removals/couwdecision_sign.doc. Accessed Decem-
that pathological liars usually have sound judgment ber 13, 2003
in other matters. As stated earlier, this observation 2. Robinson WV: Professor’s past in doubt. The Boston Globe. June
makes it difficult to prove that the pathological liar 18, 2001, pp A1, A6
does not know that what he or she is doing is wrong. 3. Langdon J: Lies Jeffery told me. The Guardian, December 9,
1999. Available at http://www.guardian.co.uk/comment/story/
When pathological liars deliver obviously false tes- 0,3604,246410,00.html. Accessed November 6, 2002
timony under oath, is it legitimate to characterize 4. Smith D: Master storyteller or master deceiver. The New York
such testimony simply as perjury or do these individ- Times. August 3, 2002, p B7
5. Healy P, Robinson WV: Professor apologizes for fabrications. The
uals deserve better framing of their behavior to get Boston Globe. June 19, 2001, pp A1, A12
some dispensation from being held to the usual stan- 6. Delbruck A: Die pathologische Luge und die psychisch abnormen
dards of truth-telling? Judge Couwenberg repeatedly Schwindler: Eine Untersuchung uber den allmahlichen Ueber-
gave false testimony under oath but the commission gang eines normalen psychologischen Vorgangs in ein pathologis-
ches Symptom, fur Aerzte und Juristen. Stuttgart, 1891, p 131.
observed that he did not have any mental condition Translated by Healy W, Healy MT: Pathological lying, accusation
that excused or mitigated his condition. According to and swindling, in Patterson Smith Reprints Series in Criminol-
the three-judge panel sitting as masters, the posses- ogy, Law Enforcement, and Social Problems. Edited by Gault
sion of a “symptom” without any mental disorder is RH, Crossley FB, Garner JW. Montclair, NJ: Patterson Smith,
1969
of little legal consequence. Indeed, repeatedly telling 7. Bursten B: The manipulative personality. Arch Gen Psychiatry
fantastic and unbelievable lies in an administrative 26:318 –21, 1972
law setting is likely to irritate the judge and produce 8. Healy W, Healy MT: Pathological Lying, Accusation, and Swin-
dling. Boston: Little, Brown, 1926
a negative outcome. 9. Selling LS: The psychiatric aspects of the pathological liar. Nerv
A final question concerns whether a pathological Child 1:335–50, 1942
liar is competent to stand trial. Could it be argued 10. Hoyer TV: Pseudologia fantastica. Psychiatr Q 33:203–20, 1959
that the compulsively repeated lying prevents the 11. Schneider K: Clinical Psychopathology (translated by Hamilton
MW). New York: Grune and Stratton, 1959
pathological liar from effectively assisting his attor- 12. Bleuler E: Textbook of Psychiatry. New York: The Macmillan
ney in representing his case? Inability to present a Company, 1924

348 The Journal of the American Academy of Psychiatry and the Law
 Dike, Baranoski, and Griffith

13. Jaspers K: General Psychopathology (translated by Hoenig J, lated by Healy W, Healy MT: Pathological lying, accusation and
Hamilton MW). Chicago: The University of Chicago Press, 1963 swindling, in Patterson Smith Reprints Series in Criminology,
14. Fish F. Clinical Psychopathology. Bristol, UK: John Wright, Law Enforcement, and Social Problems. Edited by Gault RH,
1967 Crossley FB, Garner JW. Montclair, NJ: Patterson Smith, 1969
15. Koppen M: Über die pathologische Luge (Pseudologia phantas- 22. Risch B: Über die Phantastische form des degenerativen Irreseins
tica). Charite-Annalen 8:674 –719, 1898. Translated by Healy (Pseudologia phantastica). Allgemeine Zeitschrift fur Psychiatrie
W, Healy MT: Pathological lying, accusation and swindling, in 65:576 – 639, 1908. Translated by Healy W, Healy MT: Patho-
Patterson Smith Reprints Series in Criminology, Law Enforce- logical lying, accusation and swindling, in Patterson Smith Re-
ment, and Social Problems. Edited by Gault RH, Crossley FB, prints Series in Criminology, Law Enforcement, and Social Prob-
Garner JW. Montclair, NJ: Patterson Smith, 1969 lems. Edited by Gault RH, Crossley FB, Garner JW. Montclair,
16. Meunier R: Remarks on three cases of morbid lying. J Ment NJ: Patterson Smith, 1969
Pathol 6:140 –2, 1904 23. Enoch MD, Trethowan WH: The Ganser syndrome, in Uncom-
17. Stemmermann A: Beitrage und Kasuistik der Pseudologia phan- mon Psychiatric Syndromes. Bristol, UK: John Wright, 1979, pp
tastica. Berlin: Geo. Reimer, 1906, p 102. Translated by Healy W, 50 – 62
Healy MT: Pathological lying, accusation and swindling, in 24. Asher R: Munchausen’s syndrome. Lancet 1:339 – 41, 1951
Patterson Smith Reprints Series in Criminology, Law Enforce- 25. Raspe RE: The adventures of Baron Munchausen. New York:
ment, and Social Problems. Edited by Gault RH, Crossley FB, Pantheon Books, 1969
Garner JW. Montclair, NJ: Patterson Smith, 1969 26. Snyder S: Pseudologia fantastica in the borderline patient. Am J
18. Vogt H: Jugendliche Lugnerinnen. Zeitschrift fur Erforschung d. Psychiatry 143:1287–9, 1986
jugend. Schwachsinns Bd. 3. H. 5:394 – 438, 1910. Translated by 27. Weston WA, Dalby JT: A case of pseudologia fantastica with
Healy W, Healy MT: Pathological lying, accusation and swin- Antisocial Personality Disorder. Can J Psychiatry 36:612–14,
dling, in Patterson Smith Reprints Series in Criminology, Law 1991
Enforcement, and Social Problems. Edited by Gault RH, Crossley 28. Cleckley H: The Mask of Sanity. St. Louis: CV Mosby, 1955
FB, Garner JW. Montclair, NJ: Patterson Smith, 1969 29. Casey PR: An unusual variant of folie a deux? Irish J Psychol Med
19. Wiersma D: On pathological lying. Character Personal 2:48 – 61, 6:44 – 6, 1989
1933 30. King BH, Ford CV: Pseudologia fantastica. Acta Psychiatr Scand
20. Deutsch H: On the pathological lie (pseudologia phantastica). 77:1– 6, 1988
J Am Acad Psychoanal 10:369 – 86, 1982 31. Modell JG, Mountz JM, Ford CV: Pathological lying associated
21. Wendt E: Ein Beitrag zur Kasuistik der Pseudologia phantastica. with thalamic dysfunction demonstrated by [99mTc] HMPAO
Allgemeine Zeitschrift fur Psychiatrie 68:482–500, 1911. Trans- SPECT. J Neuropsychiatry 4:442– 6, 1992

Volume 33, Number 3, 2005 349