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University of Toronto Scarborough
Connie Boudens

CHAPTER 10: MENTALLY DISORDERED OFFENDERS AND FITNESS TO STAND TRIAL Legal Background -Western : individual is presumed innocent until proven guilty and understands the charges -purists: each defendant be equipped to have “best possible” defense…court convenience (expediency) and assessment resources are second importance -pragmatists: each defendant has ability to be defended but is also important as having an efficient judicial system *both practioners fall somewhere btw these extreme positions ROLE OF MENTAL DISORDER IN COURT Fitness to Stand Trial …*NGRI, NCR= not fit -Basic Idea: Fundamental Justice  People with mental disorders are cognitively and emotionally impaired  They may be unable to effectively participate in a legal defense  They may therefore be found guilty even if they are innocent. -competency to stand trial/fitness to stand trial: fundamental justice gatekeeper for criminal justice..that ppl facing criminal trials are competent to respond to chargers (courts rather forgive 99 guilty ppl than wrongly convict a single person) -CST assessments most freq for referral qs asked of forensic experts Legal Standards -FST established to ensure mentally disordered defendants are cognitively capable of assisting their attorneys in their legal defense -legal criteria for deciding fitness in Canada: An individual is presumed fit to stand trial unless, on account of mental disorder, the defendant is incapable of (a) understanding the nature or object of the proceedings, (b) understanding the possible consequences of the proceedings, and (c) communicating with counsel Legal Criteria: presumption of fitness unless demonstrated otherwise, responsibility of proof is on the party raising the issue, level of proof for Fitness is “balance of probabilities” Legal Criteria: Standards of Proof -four basic levels of proof required for decisions appropriate to different contexts 1. Beyond a Reasonable Doubt Application: Criminal Conviction Probability ~ 95 % and up 2. Clear and Convincing Evidence  Application: Important Non-Criminal Decisions  Probability ~ 75% to 94% (or above) 3. Preponderance of the Evidence  Application: majority of evidence points to certain thing but not overwhelmingly so  Probability ~ 65% to 74% (or above) 4. Balance of Probabilities  Application: civil cases –ex suing …who is telling most truth  Probability ~ 51% or above Taylor Criteria Canadian standard represents a very basic factual understanding of the issues  Specifically: 1. Unable on account of a Mental Disorder to:  This is the first step that requires a mental health expert;  Only a mental health expert (including psychologists) can diagnose a mental disorder, absent which Fitness is not an issue. 2. Understand nature & object of the proceedings: questions about the roles of the judge, crown attorney, defense attorney, witnesses, police, meaning of an oath, to establish a finding of guilt or innocence. 3. Understand possible consequences of proceedings: Jail/prison if guilty, Hospitalization if NCRMD, Freedom if innocent, probation (if applicable) 4. Communicate with counsel: Often inferred by mental health professional, Often best answered by attorney *who can offer opinion on fitness: Legislation says “Physician” but CPA is working to amend it to include psychologists INSTRUMENTS 1) CST -Earlier (first generation) CST : provide standardization to enhance clinicians’ efforts aid in assessing CST; focus on defendant’s understanding of the legal system (CST and GCCST) -a true screening instrument -sentence completion paradigm -22 items, score 0 1 or 2—scores below 20 suggest need for more comprehensive evaluation Neuropsych correlates of CST -provide independent free domain-free reflection of an accused ability to participate & is useful adjuncts to CST evaluations Who Should Be Referred? In most jurisdictions, the issue of CST can be raised by any of the three parties (judiciary, prosecution, or defense) at any preverdict phase of the trial. Who Can Perform CST Assessments? - Farkas, DeLeon, and Newman  found that 52 responding jurisdictions sanctioned psychiatrists to do these evaluations. 42 jurisdictions did not require any specialized certification beyond the professional license. 10 states required additional forensic certification all of which also sanction psychologists for CST evaluations. 6 of these states qualify social workers, 4 nonspecialist MDs, and 3 qualify ‘‘others.’’ Where Are CST Assessments Performed Optimally? -Prior to Allan Guttmacher’s groundbreaking establishment of the Office of the Medical Examiners in Baltimore, CST assessments were typically conducted in jail cells. This practice could threaten the integrity of the CST decision Competency Assessment Instrument (CAI) -Comprehensive semi-structured interview for use following a low CST scorer -Goes beyond cognitive criteria (e.g. Taylor) requiring appraisal of available legal defenses) -no cutoffs, but global clinical judgment after scoring is completed Recent Instruments Designed to Assist CST Evaluations 1) The Fitness Interview Test (Revised Edition) -was intended as a screening instrument (favoring overestimates of unfitness). -Semi-structured interview addressing three (post MI) criteria.  16 items in total scored 0, 1, 2  6 for understanding nature or object of proceedings  3 for possible consequences  7 for communicate with council Section 1:‘‘under- standing of nature and object of the proceed- ings’’ querying knowledge of items such as the arrest process, severity of charge, and roles of key participants at trial. Section 2 : ‘‘appreciation of personal involvement and important consequences’’ including appraising knowledge of legal defenses and likely out- come. Section 3: ‘‘capacity to communicate with counsel and participate in defense’’ and consists of items related to a variety of communicative capacities such as relate the facts of the case to the lawyer, challenge prosecution witnesses, and testify relevantly. -rated on 3 point scale (0-2 from no to severe impairment), no cutoffs for fitness -relies on clinical judgement despite requiring scores fitness= must have legal recognized mental disorder & related inability to perform any of the 3 functions 2) MacArthur Competence Assessment Tool-Criminal Adjudication. -to satisfy purist; ecological validity relating to accused incident & ability to provide answers to hypothetical legal questions -providing an incident and then asking a series of questions regarding the incident and extensions of the process 3 areas considered: -factual understanding of legal system and adjunction process -reasoning ability -specifics of defendants particular case *critique: Applies only to American system in those states that have gone well beyond a limited cognitive capacity standard, Far too high a level, especially with respect to reasoning ability and application to the defendant’s case, Almost requires the defendant to be a competent criminal attorney 3) The Evaluation of Competency to Stand Trial-Revised. -standardized interview for assessing the dimensions of CST via Dusky..first to detect whether individuals are feigning incompetence -18 items and 3 competency scales corresponding to Dusky..4 main sections with small set of background questions 4) The METFORS/Nussbaum Fitness Questionnaire. -19 item self report measure focusing on legal issues addressed during fitness interviews -screening tool to identify potential unfit individ from large number of potentially unfit/incompetent individuals -17 multiple choice items w 6 response options for each Permutation Model of Test Construction -This allows norm free inferences regarding: Fitness/Unfitness, Blatant Malingering, Subtle Malingering - Each question is structured with:  1 Correct answer (16% probability)  3 Incorrect but “in the ballpark answers” (50%)  2 Absurd answers (33%) -patients who would be screened out (ie not require extensive fitness assess) are those who score above the statistical cutoff for correct answers & responding above chance lvls & hypothetically considered FIT therefore; patients within chance lvls on any of the 3 item types require extensive assess *greater than chance of absurd items= blatant malingering; greater than chance of incorrect/ if more than a random number of Incorrect choices are selected =subtle malingering Those favoring empirical structure/semi structure to FST: need to show some relationship btw a fitness decision and objective measure of abilities within the fitness domain *neither purely clinical nor structured/semi shown superiority…best to combine Suggestions for practice In light of the above, we suggest that initial screening should proceed on a relatively broad number of individuals with an economical and cost effective screening instrument such as the NFQ. NGRI: BASIC FUNDAMENTAL JUSTICE ISSUE: A 2 year old baby knocks a lamp over that falls into a bathtub with the baby’s mother in itIs the baby guilty of murder? Should the baby be tried for manslaughter? Obviously NO to both questions!! Issue I: -In Western criminal jurisprudence, responsibility for a crime involves not only a “guilty act” (Actus Reus) but also a “guilty mind” (mens rea) babies and minors (NOT miners): deemed not to possess enough intellectual abilities to form a mens rea even in they commit an actus reus Issue II; Degrees of Culpability (fault) 1: -Murder: Crown must prove specific intent to kill while intent to injure is insufficient for a murder conviction -guilty finding for First Degree Murder= premeditation (pre event planning; malice of forethought) Issue III; Degrees of Culpability 2: -Murder in the Second Degree= requires intent to kill but it is spontaneous rather than premeditated Issue IV; Degrees of Culpability 3: -If Specific Intent Crimes cannot be proved (NO mens rea, u didn’t intend) and the victim dies, the correct charge/conviction is= Manslaughter Issue V: -degree of culpability based on the act and intent of competent people. -An “incompetent individual” likely does not have a means rea, and punishment for an actus reus absent a mens rea is seen as inappropriate punishment or punishment in absence of guilt. Issue VI: Exculpatory mental conditions and states have been recognized since ancient times. Talmudic law states (Tractate Hagiga, 3b): “A deaf-mute, an insane person and a child are bad to meet because if they damage you they are not responsible, but if you damage them, you are responsible.” An insane person is identified as someone who looses things given to him, and/or sleeps in a cemetery (deemed dangerous at the time) or other common behaviours showing a lack of acting out of self-interest. Transient states wherein an individual is not responsible was recognized as legitimate by the Talmud TRIAL OF DANIEL M’NAUGHTON -M’Naughton shot Secretary Edward Drummond in an assassination attempt at P.M. Sir Robert Peel -Gave delusional reasons claiming that the Tories were persecuting him. -Judge ruled in favor of M’Naughton receiving the NGRI defense since 9 psychiatrists said he was insane Response to M’Naughton Verdict: -Queen Victoria very upset!!...Called a commission to “explain” the ruling (actually redefined NGRI standard)Resulted in : “M’Naughton Rule” of “limited cognitive capacity:” At the time of the offense, the accused was operating under such a defect of reason resulting from a disease of the mind as not to know the nature and quality of the act, of if he did, did not know that the act was wrong Response to “M’Naughton Rule” I: “Product Rule” (New Hampshire, 1869) suggested the NGRI defense if the criminal act was the product of an existing mental disease or defect. This opened the door regarding the two salient issues: 1. Presence of a Mental Disorder or defect & 2. Whether the act was the “product” of the Mental Disorder of Defect Response to “M’Naughton Rule II” Isaac Ray: Cogent Point: Mental disorders affect volition (will to act) as well as reason! *M’Naughton addresses only one aspect of the effects of disease of the mind on ability to chose behaviours; the basis for responsibility. Response to “M’Naughton Rule III” 1900’s: No other jurisdiction adopted the Product Rule Consequences of NGRI Defense  Less than 1% of criminal cases  Successful in less than 10% of cases where it is raised…but varies by state  84% are hospitalized after NGRI  NGRI acquitees are hospitalized longer Supreme Court in Swain: Criteria: On account of a Mental Disorder, at the time of the index offense, the individual was unable to: 1. Appreciate the nature and quality of the offense Appreciate denotes both a factual and emotional knowledge and thus goes beyond mere factual and even strictly rationale knowledge There must be some emotional awareness of what it means for an act to result in its consequences, and what it means to be assaulted, experience pain, what death is all about etc. Rare in relation to NCR findings 2. Know its legal and moral wrongfulness Requires knowledge of both legal and moral wrongfulness; i.e., knowledge of either one alone is not sufficient for presumption of Criminal Responsibility Knowledge is less encompassing that appreciation Most NCR findings hinge on this prong of the defense Article: Where the Bad may be Mad From Criminal Justice Quarterly, ‘Mental Disorder’ Criminal Code of Canada as ‘disease of the mind’. - an accused may avoid criminal responsibility where: 1) he or she suffers from a mental disorder, 2) ‘mental disorder’ may include a personality disorder, 3) the mental disorder must deprive the accused of the ability to know that the act or omission is both legally and morally wrong in the eyes of society, 4) that a volitional ‘following’ of a personal or deviant moral code will not suffice, and 5) the accused must have the ability to apply that knowledge of wrongfulness in a rational way to the alleged criminal act at the time of committing the act. LAW AND CRIMINAL RESPONSIBILITY Public Misconceptions about NCRMD Misconception Reality NCRMD is commonly used Used in only 2 cases per 1,000 AKA 1/5 NCRMD defences are successful 26% success rate NCRMD acquittees commit murder 15% of NCRMD individuals charged with murder NCRMD is a loophole 13% - absolute discharge; 35% - conditional discharge; 52% - committed to a hospital NCRMD individuals are not confined for long Confined for longer than normal offender persons found guilty of similar crimes NCRMD individuals are dangerous Most do not engage in violence Mental Disorders and the DSM -Tool for diagnosing in North America: Diagnostic and Statistical Manual of Mental Disorders (DSM) -In Europe: International Classification of Diseases -10 (ICD-10) • DSM-IV-TR & DSM-V: – Five Axes of Diagnoses: Axis I: Clinical Disorders & Other Conditions That May Be a Focus of Clinical Attention Axis II: Personality Disorders & Mental Retardation Axis III General Medical Conditions Axis IV Psychosocial and Environmental Problems Axis V Global Assessment of Functioning *critique: construct validity & reliability of the categories and symptoms; btw DSM I and IV, 280% increase in number of disorders listed “everyone has a disorder nowadays” Mentally Disordered Offenders -movement to deinstitutionalize psychiatric patients began in 1960s -Higher rates of mental illness in prison population than among general community population; prisoners 10x likely to have psychiatric disorder -Mental illness in the criminal system: issues of fitness to stand trial, culpability and criminal responsibility, need for support and intervention in corrections -personality disorder: maladaptive patterns of relating, perceiving and thinking that are inflexible and serious to cause impair or dysfunction 10 p disorder clustered into : Cluster A (odd/bizarre aka paranoid, schizoid), Cluster B (dramatic/erratic aka antisocial, narc) and Cluster C (anxious/inhib aka depending, obsessive compulsive) ROLE OF MENTAL ILLNESS IN THE COURTS -when court finds UST (unfit to stand trial), must give accused conditional release OR detention within 45 days (can’t order absolute discharge) -must have 3 members (judge/lawyer, psychiatrist and third p) -Ontario appoints 5 members -when consider type of disposition.. consider: protection of the public, accused mental state, reintegration of the accused into society & accused other needs Mental State at the Time of Offence Mental disorder and culpability -M’Naughton rules (1843) -Swain Decision in 1991: -Changed wording from NGRI to NCRMD (not criminally responsible on account of a mental disorder) -if its pre-swain: you go to left tendant govener and they say do u have any evidence that ur not dangerous, the accuser says theyre a good boy and hasn’t caused a commotion and done a good model patient in the hospital then review board needs evidence that if they were outside of the hospital do u have evidence that ou wont be dangerous outside the hospital and if person says no then they are like well we will do another hearing until you present evidence kangaroo court because the patient could never give evidence… this is the problem for having the patient not aloud the community to give evidence for being s good citizen outside the hospital if they cant get out that’s why old times they wouldn’t give the ngri excuse cause they know this is going to be forever… rather just plead guilty and do a year jail time rather than plead ngri defense because they know youll be in there forever.. UNLESS if u murder or severe assault then best to plead NGRI now swain made it better with NCRMD: NCRMD Qualification Rules -Presumption of Criminal Responsibility -Burden of Proof is on Party Raising Issue, issue must be considered for NCRMD: • A person suffers from a mental disorder • He or she fails to appreciate the nature or quality of his or her acts • He or she may understand what he or she doing, but might not know it is wrong NCRMD Retention Rule -Primarily defined by Winko ruling: • Burden of proof is on the Crown to prove on the balance of the probabilities that the individual: – Represents a significant threat to the safety of the public – This threat cannot be a miniscule threat of catastrophic harm or a near certain threat of trivial harm – Foreseeable risk of significant harm MDO’s, NCRMD: Review Boards • Review Boards decide on a specific disposition for each individual case • Dispositions=what security and privilege levels are permitted for the responsible hospital to apply to the individual accused. 3 Disposition Options in NCRMD cases: • (a) Detention Order (in or out of hospital) =Privilege Levels include: Hospital & Grounds or Community -Escorted By Staff (1:1 Staff to Accused) -Accompanied by Staff (1:4 Staff to Accused) -Directly Supervised in Community -Indirectly Supervised in Community (Call @ times from places) -Work/School/Live in Community -Supervised Housing 24/8 hr.; Approved Housing. • (b) Conditional Discharge: probation • (c) Absolute Discharge; Characteristics of People Found NCRMD and UST -Latimer and Lawrence (2006): mostly male; median age of 31; most NCRMD charged with a violence offence; most common diagnosis – schizophrenia; -NCRMD more likely to have affective and secondary personality (Axis II) disorder; -UST less likely to be charged with a violent offence; -UST – mental retardation and organic brain disorders Link Between Mental Illness and Crime and Violence: Findings -Most people with serious mental disorders do not engage in violence -People with serious mental disorders are more likely to commit violence than people without mental disorderex, only 5% of schizophrenics ever commit violent crimes vs. about 2-3% or non-MD citizens -People with serious mental disorders are more likely to be victims of violence -People with both mental disorder and substance abuse are at a significantly elevated risk for violence -BOOK: Causal mechanisms linking mental disorder and violence are not clearly understood; there may be many factors other than those unique to mental illness • Not entirely true as we will see during the lecture on Risk assessment Police Attitudes Toward the Mentally Ill -Police are frontline contact; have discretion in handling cases -Cotton (2004): Police officers did not endorse negative attitudes towards mentally ill; • Felt the need for tolerance and overcoming isolation of mentally ill in society; • Need for adequate health services; • Need for specialized police training • Forensic System: Poor Man’s Mental Health System Mental Disorder and Violence: Risk Factors Specific to Mental Disorder - delusions: eronneous beliefs that involve a misinterpretation of perceptions or experiences -Delusional Categories: Bizarre (ex aliens) and Non-Bizarre (ex police are watching) Types: Delusions of (External) Control: ex false belief external forces/another p are controlling one’s thoughts/behavior Persecutory Delusions: false belief youre being followed, poisoned, spied Delusions of Grandeur: false u have super powers, are god Delusional Jealousy : false belief your partner is having affair Delusions of Reference: false belief irrelevant or unrelated events have direct significance Link & StuevePersecutory Delusions/ aka “Threat/Control Override” (TCO) symptoms: self control overridden by outside forces/feels harmed by others… most violent causing Why do some patients obey command hallucinations and others not? b/c type of command hallucinations (non-command & self harm most obey), beliefs about command (justified or from higher power obey), perception of lvls of malevolence or benevolence (beneveolnt aka god rather than satan obey), consequences (obey if it wont harm anyone) Psychopathy -encompasses symptoms from four distinct DSM-IV Axis 2 “Cluster B” Personality Disorders: Antisocial, Narcissistic, Borderline and Histrionic -a subset of psychopathic qualities are symptomatic of ASPD - ‘psychopathy’ is a ‘hard wired’ personality abnormality with a biological and / or genetic basis for the disorder The other groups of offenders reflect more circumscribed behavioural disturbances which may have been the product of learning and environmental influences in early childhood. *The difference between psychopathy and these other groups =etiology (psycho more bio) Emotional Deficits -deficit for unable to behave in pro social ways =emotion characterized by reduced sensitivity to punishments cues, muted stress response & obliviousness to distress display of others -Blair says it prohibits normal inhibition of predatory behavior Cognitive/Linguistic Deficits -Newmann says they focus their attention on most salient aspect of their enviro at expense of other potentially important info (ex if see 2 in a string of 1s, the brain responses are smaller than controls esp w tasks demanding involvement… occurs in absence of moral context) Motivational/Decision-Making Deficits -motivated by immediate opportunities for reinforcement… psychos tended to continue selecting from high-risk decks despite losing more and falling into greater depth Anomalous Neurobiological Attributes of Psychopaths -reduced frontal lobe volumes= “unsuccessful” (i,.e, detected and convicted) psychopaths but not successful psychopaths or non-psychopathic -The prefrontal cortex = abstract reasoning, behavioural monitoring and inhibitory control, freedom from impulsivity and similar “executive functions”. -inhibition (serotonin, dopamine) working memory (dopamine again), reward focus (dopamine, and again) attention and concentration (norepinephrine), activation, sex drive and reward focus (testosterone), stress and memory impairment (cortisol), thyroid hormone (energy and activation) and cholesterol (actually negatively associated with psychopathy!) Measurement of Psychopathy: - ‘Cleckley Criteria for Psychopathy’: superficial charm and good intelligence, absence of delusions and other signs of irrational thinkin,absence of nervousness or psychoneurotic manifestations, unreliability, untruthfulness and insincerity, lack of remorse or shame -Robert Hare Psychopath Checklist (PCL-R): best and most reliable; checklist w two factors (1: interpersonal/affective traits & 2: presence of antisocial behaviors) -first factor= neg correlated w measure of empathy & anxiety, positive corr w narcissism and Machiavellian -second= antisocial p disorder, criminal behave, socio status -score of 30 out of possible 40 is psychopath -Self-Report Scales (Psychopathic Personality Inventory-Revised; Self-Report Psychopathy Scale) Could the psychopath be found not criminally responsible on account of mental disorder?-->yes if meet above points listed above (like any other disorder). Where psycho is an extreme form is in best position to avail (advantage) himself of this defense The ‘Floodgate’ Problem: Why it will not be a problem. While the psychopath may theoretically find himself in a position to avail himself of the defense of not criminally responsible on account of mental disorder it is very unlikely that this will ever be seen as an attractive option under Canadian law. Assessing Psychopathy in Youth -Self-report and rater-based assessments -Scales: Youth Psychopathic Traits Inventory, Antisocial Process Screening Device, Hare Psychopathy Checklist: Youth Version -issues: negative consequences, possible psycho traits common features of normal developing youth, & stability of psycho traits from child-adolescence and to adult Psychopathy and Criminal Responsibility • Pre-Swain (1991; LGW System) – Psychopathy and severe Antisocial Personality Disorder (APD) did qualify for a NGRI (Mental Health) Defense – Burden of Proof on accused to prove that he was no longer “Dangerous” • Post-Swain (after 1991; Review Board System) – Psychopathy and severe APD do not qualify for a NCR Defense Psychopathy: Associations with Crime, Violence, and Recidivism • Strong link between psychopathic traits and criminal and aggressive behaviour • Begin criminal career at an early age, persist in violence across the lifespan • Engage in high-density offences and predatory aggression Features that explain psychopaths’ engagement in violence and crime: • Sensation-seekers and risk takers (put themselves in high-risk situations) • Impulsive (fail to consider alternatives & consequences) • Unemotional (do not appreciate consequence on others) • Suspicious (perceive hostile intent) • Selfish and arrogant (want power and control over others) Theories of Psychopathy -Cleckley (1941): poverty of emotionsdeficit is poverty of emotions -Lykken (1995): low-fear hypothesis -Hare (2003): affective deficits -Developmental psychologists: importance of emotion in developing conscience; psychopaths show reduced autonomic responses to distress of others not learn to inhibit their behaviours Genetics of Psychopathy • Moderate to strong genetic influence • This does not imply immutability • Interventions should be undertaken as early as possible Biological Basis for Psychopathy -Weber, Habel, Amunts, Schneider (2008): various brain abnormalities involve a network -Functional neuroimaging studies used to provide insight into the areas of brain implicated in psychopathy Treatment of Psychopaths • Should not be considered untreatable • Treatment programs should be high-intensity, cognitive-behavioural • Providers should be familiar with cognitive and emotional processing deficits • Intervention should be early • Treatment should target treatment-interfering behaviours POLICE INTERREGATION TECHNIQUES (THROUGH CASE OF RUSSELL WILLIAMS) Russell Williams -ppl he worked with didn’t believe he could have done this… he is loving to his people -loving husband to mary Elizabeth hairman… he was considered loving (and wasn’t ABUSIVE …strange. b/c paul bernardo hit his wife), and this couple was a power couple (they were smart and had a really good job that paid a lot of money)…they spent a lot of time apart (he has huge opportunities to encounter a lot of women, had a lot of freedom b/c it was a commute marriage), **this is common for the wife to be ignorant of their husband to be a serial killer..but the fact they lived apart a lot is an indicator Williams interviewed to Jim -Not eligible for “faint hope clause” (he will never have the opportunity to walk free ) *it takes 60 break and enters for his behaviour to escalate.. did he admit to everything? Not sure..maybe he’s killed more or something Victims – Break, Enter, Theft -48 Residences (23 Tweed; 25 Ottawa) -Targeted the homes of attractive adult women, but many of the break and enters targeted children's (age12..prepubescent) rooms and undergarments. -Everything the does he records it on a spreadsheet and takes photos and videos and filed them into harddrives that he hid in the Ottawa home (why hide it in the house his wife spends most time rather than the Tweed cottage location where she doesn’t visit?). he is very organized. The photos he takes are him masturbating naked with the garments he took -B&E’s committed over night, he picked locks, went into basement windows, … he is so confident that no one is going to notice or call the police because he fits in with society -He took the passports and identity because he is gathering data on them. He likes to invade their privacy and he feels in control of invading, he gathered so many trophies (lingeries, bras, panties…) so much he had to burn them to start over Most of his victims he doesn’t know, peeping tom and decided if they will be his victim or not He follows same process with every attack… he uses a flashlight He writ
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