"In talk, mark carefully what is being said, and when action is afoot, what is being done."
Marcus Aurelius Antoninus, Meditations

John J. Baeza & Brent E. Turvey, MS
May, 1999

"Sadistic Behavior: A Literature Review"

Baeza, J. & Turvey, B., "Sadistic Behavior: A Literature Review," Knowledge Solutions Library, Electronic Publication, URL: http://www.corpus-delicti.com/sadistic_behavior.html, May, 1999

Note: Brent E. Turvey, MS is a full partner of Knowledge Solutions, LLC.
He can be reached for comment or consultation by contacting:
Knowledge Solutions; 61535 S Hwy 97, #9-148; Bend, OR 97702
Phone 541-318-8293; Email:

John J. Baeza is a sex crimes Detective with the New York Police Department
in the Manhattan Special Victim's Squad. He can be reached for comment
by email at:

The purpose of this paper is to review and discuss the application of the term sadistic to descriptions of offender crime scene behavior within the existing psychiatric and criminological literature. In doing this, the authors will discuss established terms, definitions and standards of evidence related to the concept of sadism, the confusion between behavioral prediction and analysis as evidenced in the literature, and attempt to expel myths regarding behaviors that have been erroneously assumed to be sadistic in nature. These issues will be elucidated by examples from that literature of offenders whose behavior has been labeled sadistic, in terms of whether or not they meet a proposed behavioral standard. This proposed standard was inferred by the authors from historical accounts regarding the behavior and writing of the Marquis de Sade, from the descriptions provided by the Psychopathia Sexualis, and from the criteria provided by the Diagnostic and Statistical Manual of Mental Disorders, 4th Ed. (1994).

The above is with the caveat that standards used in a treatment setting (where treatment models can involve the creation of therapeutic fictions irrespective of the established facts of a case) are necessarily less rigid than standards that can or should be employed in an investigative or courtroom setting. Treatment sometimes concerns itself only with what the patient believes to be true regarding offense behavior. Investigative efforts and courtroom analysis require that forensic opinions be based upon the established facts of a case. As such, this work confines itself to a review of those instances in the literature related to analysis and interpretation of offender behavior as it is argued from established offense related behavior.

There has been in general parlance, and the mass media, an accepted use of the term sadistic to describe a wide variety of criminal behaviors. Most often it is used to describe any perceived cruel act without respect to specific motivation or context. Learned professionals have not advanced much beyond this vaguely defined usage. In the investigative community, it may be used to describe the motive of a serial rapist. In the criminological community it may be used to define an offender group that is being studied for shared characteristics. In the clinical community, it may be used to describe the fantasies of a patient. In some cases the application of this term may be appropriate and accurately convey what is meant by its invocation. In other cases, however, the application may be inappropriate, and arguably misinformed by the sensationalistic and inconsistent body of literature that has come into existence on the subject of sadism. Professional usage of the term is often broad, equating the enjoyment of any cruel act with sadism, and often tainted by moral umbrage instead of scientific objectivity.

Despite the persistent interest of professionals and the public in the employment of this term as a descriptor, a literature review performed by the authors evidenced surprisingly little in the way of scientific research regarding the specific concept of sadism, as either a diagnosis or a behavioral descriptor. The literature did evidence a lack of consistency in the way that professionals define sadism and in the way that the standard of sadism is applied on a case by case basis. Furthermore, there was found a marked propensity for broadly inclusive generalizations regarding the types of behaviors, and offenders, that should be described as sadistic.



The term sadism is derived from the name of a French author who lived from 1740 to 1814, Donatien-Alphonse-Francois de Sade, better known as the Marquis de Sade. His existing body of work is regarded by many as important erotic literature, because it effectively, intelligently, and indelibly rendered descriptive images of sexual arousal driven by physical suffering. This passage from Justine (de Sade, 1990), for example, describes sadistic rape behaviors inflicted by a monk for the purpose of achieving sexual gratification through his victim's pain and humiliation:

"He spreads, he presses, thrusts, tears, all of his efforts are in vain; in his fury the monster lashes out against the altar at which he cannot speak his prayers; he strikes it, he pinches it, he bites it; these brutalities are succeeded by renewed challenges; the chastened flesh yields, the gate cedes, the ram bursts through; terrible screams rise from my throat… Never in my life have I suffered so much.

…Inflamed by lust, the beast strikes with all his force… daring to mix love with these moments of cruelty, he fastens his mouth to mine and wishes to inhale the sighs agony wrests from me…"

De Sade spent 27 years of his adult life in prisons, dungeons, and asylums throughout France for reasons that included "excesses committed in a brothel," kidnapping and sexual assault, poisoning, and homosexual sodomy (Seaver and Wainhouse, 1990). As one example taken from many, his known criminal enterprises included, in 1768, luring an unemployed cotton spinner named Rose Keller (whom he found begging in the street) to a rented cabin under the pretext of giving her some form of assistance. Once there, however, he ordered her to undress, threatened her with a knife, and, over the course of several hours, whipped her severely.

The Marquis de Sade and his publisher were both arrested by the Minister of Police in 1801 for writing and publishing Justine, and the "still more terrible work, Juliette," (Seaver et al, 1990). De Sade was not allowed a trial, but rather put directly in prison as an "administrative punishment" to spare the country a scandal. Before long, his detractors had him declared insane, and transferred to Charenton Asylum, where continued efforts were made to silence his pencils and subsequent influences on the outside world. He died at Charenton Asylum in 1814 of failed health.

The term sadism was adopted for professional use by Krafft-Ebing in 1898, classified as one of the sub-divisions of paraesthesia (a perversion of the sexual instinct) and evidenced by the following:

"It consists in this that the association of lust and cruelty, which is indicated in the physiological consciousness, becomes strongly marked on a physically degenerated basis, and that this lustful impulse coupled with presentations of cruelty rises to the height of powerful affects…

The quality of sadistic acts is defined by the relative potency of the tainted individual. If potent, the impulse of the sadist is directed to coitus, coupled with preparatory, concomitant or consecutive maltreatment, even murder, of the consort ("Lustmurder"), the latter occurring chiefly because sensual lust has not been satisfied with the consummated coitus."

Arguably this definition can be reduced to the idea that sadism was thought to involve sexual gratification achieved through the cruel treatment and subsequent suffering of a "consort" (i.e. - a spouse, partner, or victim). In keeping with this definition, Kraft-Ebing (1898) adduces a total of 15 sadistic cases. Each case but one consistently involves an argument that the offender tortured a conscious creature for the purposes of achieving sexual gratification. The exception, case no. 25, involves a patient who developed an adolescent association between seeing blood flow from the fingers of females and his own sexual arousal, an image which made its way into his sexual fantasies but never manifested itself with an actual victim.

Sadism was not necessarily associated with criminality or murder. According to Kraft-Ebing (1898), when sadistic acts did result in homicide, these could be referred to as "Lustmurder." In this paradigm, the classification of a homicide as a Lustmurder requires that the cruel treatment, which can include but is not limited to "strangling, stabbing, and flagellation" (Krafft-Ebing, 1898), is indeed oriented towards the sexual gratification of the offender. In other words, the application of the term Lustmurder assumes offender behavior services primarily sexual desires.

Furthermore, while all sadistic murders may be classified as Lustmurder, not all Lustmurder involves sadism. Kraft-Ebing adduces a total of 13 cases of Lustmurder, only one of which is also sadistic. In fact, the majority of the cases presented involve quick deaths for the victims and postmortem activity such as sexual penetration, blood drinking, evisceration, organ removal, or mutilation. From this we can reasonably infer that the homicidal classification of "Lustmurder" suggested by Kraft-Ebing was indeed intended to be used as a non-specific and intentionally inclusive term to describe almost all sexually motivated crimes that involve homicide, not just sadistic ones. Arguably, this is no different in application than the broadly inclusive term "Sexual Homicide," proffered by Burgess, Douglas, and Ressler (1988), referring to "the killing of a person in the context of power, sexuality, and brutality."


Defining Sadism: A Proposed Standard

For the purposes of this review, a behavioral requirement to establish evidence of sadism was inferred from the background provided above, as well as the DSM-IV (1994):

"The paraphilic focus of Sexual Sadism involves acts (real, not simulated) in which the individual derives sexual excitement from the psychological or physical suffering (including humiliation) of the victim. Some individuals with this Paraphilia are bothered by their sadistic fantasies, which may be invoked during sexual activity but not otherwise acted on; in such cases the sadistic fantasies usually involve having complete control over the victim, who is terrified by anticipation of the impending sadistic act. Others act on the sadistic sexual urges with a consenting partner (who may have Sexual Masochism) who willingly suffers pain or humiliation.

Still others with Sexual Sadism act on their sadistic sexual urges with non-consenting victims. In all of these cases, it is the suffering of the victim that is sexually arousing. Sadistic fantasies or acts may involve activities that indicate the dominance of the person over the victim (e.g., forcing the victim to crawl or keeping the victim in a cage). They may also involve restraint, blindfolding, paddling, spanking, whipping, pinching, beating, burning, electrical shocks, rape, cutting, stabbing, strangulation, torture, mutilation, or killing."

From the above definition, a basic behavioral standard can be inferred, which we propose should be required to warrant the use of the term sadistic when describing offender behavior:

Some authors suggest that necrophilic and other postmortem behaviors are sadistic in nature. In agreement with Dietz, Hazelwood, and Warren (1995), the proposed standard reaffirms that any behavior taking place after a victim is unconscious or deceased does not meet the burden required for use of the descriptor sadistic:

"The critical issues are whether the victim suffered, whether the suffering was intentionally caused, and whether the suffering sexually aroused the offender. This is why neither sexual nor cruel acts committed on an unconscious or dead victim are necessarily evidence of sadism; such a victim cannot experience suffering."

Further still, some authors make a distinction between the term "sadism" and "sexual sadism," arguably to accommodate the expanded usage that has evolved in general parlance. The proposed standard reaffirms that sexual gratification is inherent to sadistic behavior, distinguishing it from other forms of cruelty. This is in keeping with the origins of the term, born out in the behavior and lifestyle of the Marquis de Sade (Seaver et al, 1990) and described in the Psychopathia Sexualis (Krafft-Ebing, 1898). As such, the term "sexual sadism" is considered redundant.

This standard is proposed with the thought that while many offenders may or may not have sadistic fantasies, what is at issue for investigative or courtroom purposes is the nature and extent of actual behavior. Using this standard, which we have demonstrated shares a professional and historical basis, the authors proceeded to evaluate offender behaviors that have been described as sadistic in the existing literature.


Predictions and Assumptions: The Confusion of Sadism and Lustmurder

Analysis arguably involves the systematic consideration of facts to form conclusions. Predictions are the "guesses" that one entertains based, presumably, upon some form of analysis. Assumptions, on the other hand, are those items that have been accepted as truth or fact without proof.

As already discussed, "Lustmurder" has been defined (Kraft-Ebing, 1898; Holmes, 1991) as any sexually motivated homicide, without respect for sadism. It is a broadly inclusive term that can arguably be used to describe almost any homicide with a sexual element, and includes sadistic homicides. It also includes the many forms of non-sadistic homicide that can occur.

There are many examples in the literature of authors who either make the assumption that the term sadist and the term "Lustmurder" (or some equivalent) are synonymous, or who use the occurrence of postmortem "Lustmurder" behaviors to predict that the subsequent offender is a sadist (Bain, Dickey, Hucker, Langevin, Wortzman, and Wright, 1988; DeBurger and Holmes, 1988; Langevin, 1990; Holmes, 1991; Geberth, 1996; Simon, 1996; Birnes and Keppel, 1997; Geberth and Turco, 1997).

One example of a prediction of sadism based on the assumption that postmortem "Lustmurder" behaviors and sadism are synonymous includes Birnes et al (1997). In this work, the authors argue that "If the crime scene looks as though the killer spent time sexually manipulating the victim after death, then he was probably an excitation [sadistic] killer."

Another example includes Geberth et al (1997). In this work, the authors assume that "Lustmurder" involves sadism regardless of victim suffering, based on the prediction that such offenders may be fantasizing about victim suffering either in the crime scene or at a later time.

"De River recognizes that even though the offender may not witness any prolonged degree of suffering on the part of the victim, he is likely to "[call] upon his imagination and fancy to supply him with the necessary engrams to satisfy his craving for his depravity." This is not unlike lust murderers who torture victims before killing them, and then recall "an after-image (engram) of the sensation produced by the physical torture and mutilation, extending beyond time and space." The sadistic scenario is thus conjured in the imagination, be it a recreation of the actual crime scene, or the product of fantasy. In each instance, lust murders are viewed as the behaviors of sadistic sexual psychopaths."

Predictions and assumptions are not facts, and fantasy is not behavior. This distinction may not be important in a treatment setting. However, as will be discussed, it is crucial in the process of investigative and forensic work where analysis and opinion cannot assume behaviors for which there is no evidence. Further examples of this confusion are elucidated throughout the rest of this work, and its impact discussed in the conclusion.


Definitions in the Literature

Over the years, many learned authors have attempted to describe or otherwise elucidate the conditions of sadistic offenders. The result has been quite mixed. In this section, we will review some of the more prominent and commonly referenced descriptions of sadism, and discuss their veracity in terms of both clarity and adherence to the standard we have proposed.

Burgess, Groth, Holmstrom, and Sgroi (1978) describe sadism by stating that:

"The sadistic offender finds pleasure in hurting the child… Sexuality becomes an expression of domination and anger. In some way the child symbolizes everything the offender hates about himself, and thereby becomes an object of punishment. The victim's fear, torment, distress, and suffering are important and exciting to the sadistic pedophile, since only in this context is sexual gratification experienced… His intention is to hurt, degrade, defile, or destroy the child. Sexuality and power are in the service of anger."

This definition appears to be in conflict with itself. The issue of sexual gratification from victim suffering is appropriately raised, however it is sandwiched within the concept that sexuality and power are servicing aggression and anger. When sexuality and power service anger and aggression, those associated behaviors are best described as anger-retaliatory (see Generalized Behavioral Assumptions below), and not as sadistic. Sadistic behaviors actually involve the use of anger and aggression in the service of sexual gratification. Readers adhering to this conflicted definition might proceed to confuse anger-retaliatory behavior for sadistic in their casework.

In his subsequent work, Groth (1979) described sadism by stating that:

"There is a sexual transformation of anger and power so that aggression itself becomes eroticized. The offender finds the intentional maltreatment of his victim intensely gratifying and takes pleasure in her torment, anguish, distress, helplessness and suffering.

…Usually his victims are strangers who share some common characteristic, such as age, appearance, or occupation. They are symbols of something he wants to punish or destroy.

…Excitement is associated with the inflicting of pain upon his victim… Hatred and control are eroticized, so that he finds satisfaction in abusing, degrading, humiliating, and in some cases, destroying his captive."

Again, this presentation appears internally conflicted. It appropriately argues the eroticization of aggression and the need for victim suffering, but then goes on to emphasize what can only be described as non-sexual anger-retaliatory motivations involving hatred, punishment, and victim destruction. Again, readers adhering to this definition might proceed to confuse anger-retaliatory behavior for sadistic in their casework.

Cleckley (1988), on the other hand, stretches his description of psychopaths to include an element of sadism:

"In a broader sense it might be said that the apparently willful persistence with which they bring humiliation and emotional suffering upon those who love them, as well as failure and unpleasant circumstances upon themselves, marks all psychopaths as both sadists and masochists. Only in this sense, however, are these impulses common or consistent, and the gratification is probably not the directly erotic sensation enjoyed by perverts who literally whip others or have themselves whipped."

This usage of the term sadism ignores two requirements. In an applied sense, it either assumes the intent of the offender to cause suffering, or ignores the issue of offender intent altogether. Furthermore, it purposefully removes the requirement of achieving sexual gratification through victim suffering. It ultimately suggests that general cruelty and sadism are really the same thing, regardless of intent or context. While it is possible that Cleckley was being somewhat facetious in this discussion of sadism, in the overall context of his work a reader may not be certain. Therefore, readers adhering to this generalized description might proceed to infer that all psychopaths are also sadists; sadistic behavior may be assumed and not established, in subsequent case analysis.

Langevin (1990) gives a description of sadism that appears to associate it with features of the more inclusive "Lustmurder":

"Sadism is a sexual anomaly whereby an individual derives sexual gratification from the power and control over his victim, from their fear, terror, humiliation, and degradation, as well as from their injury and death… Usually sadists are men who are aroused as much by the force and power as by the sexual acts. They may also engage in bizarre ritualistic behavior and, in conjunction with the sexual entrapment of their victims, they may be sexually aroused by the unconscious or dead body."

This definition is somewhat appropriate and arguably meets the proposed standard for sadism. However, it is potentially confusing because it mentions the possibility of postmortem activity and arousal without qualification. While it is possible that an unconscious or dead body may arouse some sadists, this arousal is non-sadistic and requires separate discussion and description. In a discussion about the defining characteristics of sadistic behavior, the discussion of non-sadistic traits that may be associated with them should be properly qualified to avoid potential confusion.

De Burger (1988), Holmes (1991), and Holmes and Holmes (1996) propose a serial killer typology that includes visionary, mission oriented, hedonistic, and power/control types. In particular, the hedonistic type is broken further into two categories: the lust-oriented killer and the thrill-oriented killer. According to De Burger (1988):

"Both the lust and the thrill-oriented types of killers may be sadistic with their victims. Yet, unlike the lust killer, the thrill-oriented murderer is primarily impelled to kill not by sexual motives but by a craving for excitement or bizarre experiences. In short, the act or process of killing is enjoyable for this kind of serial murder."

This description inappropriately gives the impression that thrill-oriented killers, who are not sexually motivated, may be referred to as sadistic. If thrill oriented killers are not sexually motivated, then by definition they cannot be referred to as sadistic.

Of the lust-oriented killer, Holmes (1991) argues further that:

"This type of serial killer is motivated by the hunger for sexual gratification. Unfortunately, many such killers are sadistic to the extent that their sexual pleasure depends on the amount of torture and mutilation they can administer, and ultimately on the killing of their victims."

This description directly associates sadism with victim mutilation and victim killing. Given that Holmes (1991) gives an example where victim mutilation is inflicted postmortem immediately following this description, it is worth noting that victim mutilation is only sadistic when it is carried out with a living, conscious victim. This must be established by a forensic reconstruction and cannot be assumed. It is further worth noting that the act of homicide is not necessarily sadistic in nature (even when sexually motivated), and is often ancillary to an occurrence of sadistic behaviors.

Furthermore, Holmes (1991) defines sadism as "sexual gratification received from the punishment of another person." And further states of sadistic rapists that they "seek revenge and punishment from another person by the use of violence and cruelty. The victim is typically only a symbol of the source of his anger."

As with other authors, these definitions are conflicted. It appropriately argues the eroticization of aggression, but ignores victim suffering and emphasize what can only be described as non-sexual anger-retaliatory motivations involving punishment and displaced rage. As Dietz et al (1995) warns in general, readers adhering to such a definition might proceed to confuse anger-retaliatory behavior for sadistic in their casework.

Dietz, Hazelwood, and Warren (1990), Burgess, Burgess, Douglas, Ressler (1992), and Dietz Hazelwood, and Warren (1996) collectively argue that "A sexual sadist is someone who has established an enduring pattern of sexual arousal in response to sadistic imagery." This description is ambiguous, as the term "sadistic imagery" is not defined. It could refer to imagined behavior, or it could refer to actual behavior, or both. In any case, it is not commonly regarded as a helpful practice to use the word being defined in its own definition.

Fortunately, Burgess et al (1992) does provide helpful, accurate elucidation for readers by adding, "The offender derives the greatest satisfaction from the victim's response to torture." And further still, "The offender's sexual arousal is a function of the victim's pain, fear, or discomfort."

Myer (1995), who wrote authoritatively on the subject to coincide with the effort put forth in DSM IV (1994), may only add to the confusion. While giving the DSM IV criteria for sexual sadism, he goes on state without adequate discussion that "Some consider necrophilia the most extreme form of sexual sadism, since the power to resist is nullified and the subjugation of the sexual object is complete." Interpreting necrophilic behavior as sadistic ignores, again, the requisite victim suffering to sexually arouse the offender. The dead cannot suffer.

Perhaps one of the most helpful and informed renderings of sadism, however, can be found in Dietz et al (1995).

"Sexual Sadism is a persistent pattern of becoming sexually excited in response to another's suffering… Inflicting pain is a means to create suffering and to elicit the desired responses of obedience, submission, humiliation, fear, and terror."

There is very little room for misinterpretation in this definition, and it easily meets the proposed standard for sadism. The authors also do readers the important service of explaining that sadism and criminality are not necessarily the same thing, and that there are many criminal behavior patterns that are routinely confused for sadistic, including anger or revenge motivated cruelty and postmortem mutilation.


Case Examples

Throughout the literature, reference is made to certain high profile cases as exemplars of sadistic behavior. These often involve "serial murderers" whose crimes have been sensationalized not only through all but fictional "true crime" novels, but in the media as well. This section will review the most prominent of these cases, discussing offenders whose behaviors have been inappropriately labeled sadistic, and offenders that actually exhibit sadistic behavior.


Jerome Brudos: Jerry Brudos, a thirty year old father of two who lost his job as an electrician just months before his arrest, was alleged by authorities to have been responsible for the strangulation deaths of (Turvey, 1994):

Brudos was arrested, pleaded "innocent by reason of insanity", made a confession, and mental exams were ordered. After the courts declared him "sane", he recanted his confession and was subsequently convicted on three counts of murder. He was not tried or convicted for the murders of Linda K. Slawson or Janet Shanahan.

According to information and opinions given in Holmes (1991), Brudos was best described as a "Lust Killer":

"Elaborate stalking, carefully planned activities regarding the extermination of the victim, and sexual experimentation after death (necrophilia) are often elements in lust killings; mutilation of the victim is often perpetrated as well. Jerry Brudos, a serial killer from Oregon, was such a killer."

According to information and opinions given in Geberth et al (1997), however, which are based on accounts of Brudos' crimes rendered by the imagination of a true crime author:

"Jerry Brudos, dubbed "The Lust Killer," murdered four young women during 1968 and 1969 in a series of lust murders that were predicated on a sadistic and bizarre plan to kidnap and kill women, whom he would force to dress and pose in various sexually provocative positions…

The behaviors… are appropriately described as psychopathic sexual sadism."

More specific information upon which these conclusions are made can be found in Geberth (1996). Here Geberth opines of Brudos' offense behavior with his victims, the majority of which are fetishistic and postmortem, "… In each case the victim was taken to his garage workshop, which he had equipped for this purpose and where he acted out his sadistic sexual fantasies." Geberth relates only two case examples where premortem behavior (other than that related to victim acquisition) is significant. According to Geberth (1996), regarding Brudos' behavior with Karen Sprinker:

"[The victim] …was brought to his garage workshop alive. He had sexual intercourse with the victim and then took pictures of her dressed in various stolen undergarments which he had in his collection. He then strangled her. He performed necrophilia with the corpse and then cut off both her breasts to make plastic molds."

Furthermore, according to Geberth (1996), regarding Brudos' behavior with Linda Salee:

"He took her to his garage, where he strangled her as he was raping her. He then hung her corpse from a hook in the ceiling and undressed the body, which he subjected to electrical charges to see if he could make the body dance."

As argued, however, none of the behaviors related by Holmes (1991), Geberth (1996), or Geberth et al (1997) truly satisfy the proposed standard for sadistic behavior. While easily fitting into the vague and inclusive category of "Lustmurder", Brudos' sexual desires were geared towards non-interactive or deceased victims. He did not intentionally torture his victims before killing him. Nor was victim suffering demonstrably associated with sexual arousal. Rather he had strong necrophilic (postmortem) desires associated with fetishism.

Nathaniel Code: According to information and opinions given in Burgess et al (1992), Nathaniel Code was best described as an anger-retaliatory offender, evidencing rage and overkill in his offense behavior:

"Nathaniel Code… killed eight times on three separate occasions. The first homicide, a twenty-five-year-old black female, occurred 8 August 1984. Code stabbed her nine times in the chest and slashed her throat.

Approximately one year later on 19 July 1985, Code struck again, this time claiming four victims: a fifteen-year-old girl, her mother, and two male friends. Code nearly severed the girl's head from her body. Her mother died from asphyxiation and was draped over the side of the bathtub. Code shot one of the males in the head, leaving him in the middle of the bedroom. The other male was found in the front bedroom, shot twice in the chest with his throat slashed.

The last case took place on 5 August 1987. The victims were Code's grandfather and his two young nephews, ages eight and twelve. The boys died of ligature strangulation. Code stabbed his grandfather five times in the chest and seven times in the back…

Nathaniel Code had a very distinctive calling card. The injuries suffered by the victims demonstrated one aspect of his signature. Code employed a bloody method of attack and overkill… Code wounded nearly all of the victims far beyond what was necessary to cause death (overkill).

…Code forced the mother to witness her daughter's death as part if his ritual of control, formed from his rage. If the victim's response threatened his sense of domination, Code reacted with anger and the excessive violence that led to overkill.

…In all three cases, the victims were bound with electrical appliance or telephone cords acquired at the scene… He used a handcuff style configuration, with a loop around each wrist. He also bound the ankles handcuff style and connected them to the wrists by a lead going through the legs." "

As argued in this description, Code's offenses contained a theme of domination and control, driven by rage and not sexual gratification.

As argued by Birnes et al (1997):

"There was also a shift from an ultimately unsatisfying assault in the primary sexual continuum-the killer ejaculated at the first homicide-to the concentrated use of secondary sexual mechanisms to produce a pathological sense of power-the killer's anger was the focus of the assault, and not sexual satisfaction."

And they go on to argue:

"Nathaniel Code's sexual satisfaction… made its appearance indirectly and was defused. His major concentration was the substitution of sexual release through an expression of power exhibited through ritualistic binding and cutting of his victims. In other words, the process of carrying out his anger through torture and forced submission substituted for sexual gratification"

This seems to be somewhat in agreement with Burgess et al (1992). However, Birnes et al (1997) presents the Code case as their primary example of sadistic behavior in a crime scene. Having repeatedly argued that anger and rage are being serviced by this offender's behavior, such a classification seems paradoxical. Readers adhering to this conflicted description might proceed to confuse anger-retaliatory behavior for sadistic in their casework.

Ted Bundy: Perhaps the most commonly analyzed serial murderer in the literature is Theodore (Ted) Robert Bundy, who was 43 years old when put to death for his crimes in 1989. He is credited with having killed at least 20 victims from January of 1974 to February of 1978, though he has confessed to many more. His known victims were females, ages 12 to 26, spanning the United States across Washington, Oregon, Utah, Colorado, and Florida. He is widely referred to as a psychopathic sexual sadist.

Simon (1996) notes generally of Bundy's offense behavior:

"With his arm in a cast, he would get them into his car, or to some isolated spot, and then bludgeon them with a short crowbar concealed in the removable arm cast. While the women were unconscious or semiconscious, he would then commit gross sexual acts, including anal assault. Bundy bit various body parts, sometimes biting off a victim's nipple or leaving bitemarks on her buttocks. He killed the victims by strangulation. He mutilated and decapitated their bodies, and severed their hands with a hacksaw. He would leave the bodies in secluded spots and return to them after several days to commit necrophilic acts such as ejaculating into the mouth of a disembodied head."

Birnes et al (1997), opining on Bundy's fantasies and motivations, argues that:

"He wanted to attack only those who didn't know him and to make sure they were unconscious or dead as soon after he met them as was possible. He was a necrophile who carried his victims over the threshold of death where he could exercise complete control over their corpses. That was the only relationship his fantasy allowed him."

And, later:

"Ted's intention was to spend his time with dead victims, not put himself in jeopardy by dealing with live ones. That's why he knocked his victims out almost immediately, transported them to a dump site, and murdered them so that he could experience sexual gratification through necrophilia."

There are numerous accounts of Bundy's necrophilic and other postmortem fantasy-oriented behavior related in the literature. None of them relate behavior that could be described as sadistic. There are, however, behavioral instances worth discussing.

Firstly, during an interview with SSA Bill Hagmaier of the FBI, Bundy stated that after he kidnapped Janice Ott and Denise Naslund from Lake Sammamish on July 14th, 1974, one of them had to watch the other be killed (Geberth, 1996). Given the context of this offense, and subsequent postmortem activity, sadistic intent cannot be reliably argued regarding this act. Bundy's preferred behavioral interaction was with an unconscious or deceased victim, therefore the fact that one victim had to watch the other be killed was ancillary to Bundy's primary motives. This, of course, assumes that Bundy was being truthful in his account. He was well known for his elaborate deceptions.

Secondly, one of the two victims that Bundy killed at the Chi Omega sorority house in Tallahassee, Florida on January 15, 1978 had been bitten (Geberth, 1996). Some might argue that this constitutes a sadistic act. However, arguments relating to the bitemark in the literature do not discuss whether the victim was conscious, unconscious or deceased when the bitemark was inflicted. This would need to be established before an informed behavioral analysis could be made. Further still, the context of the biting is during what could be described as violent rage. So, even if the bite was inflicted premortem, it arguably did not occur in the required context for sadistic intent.

Finally, as referenced by both Geberth (1996), and Simon (1996), Bundy is known to have given the following statement which, at face value, might be interpreted by some as evidencing a sadistic fantasy:

"You feel the last bit of breath leaving their body. You're looking into their eyes. A person in that situation is God! You then possess them and they shall be a part of you, and the grounds where you kill them or leave them become sacred to you, and you will always be drawn back to them."

Upon closer analysis there is no mention of sexual arousal and gratification, and there is no discussion of prolonged victim agony or suffering. This statement is arguably about power and control only. It does not refer to achieving sadistic needs.

Jack the Ripper: Perhaps the most infamous and sensationalized serial murderer of all time is the self-named "Jack the Ripper". He is credited with having killed at least 5 female victims between August 31 and November 9, 1888, in the Whitechapel section of the East End of London.

According to Eckert, (1981):

"Each victim was a woman of the streets who was a heavy drinker and apparently heavily intoxicated when she was killed. All except one were strangled, had their throats cut, and were mutilated after they were killed. The victim who was not mutilated was strangled and saved from desecration when the killer was startled and interrupted before carrying out postmortem mutilation. The last victim was killed indoors, and all deaths occurred late in the evening or in the early morning hours. "

This killer was never identified, and subsequently never apprehended.

At least one heavily referenced work has described these offenses as sadistic: "His two assaults were ritualized, compulsive, and highly sadistic, much along the lines of the classic case of Jack the Ripper," (Burgess et al, 1992).

However, interpretations rendered in Eckert (1989) and Turvey (1999) point towards a demonstrably non-sadistic offender who evidences both anger-retaliatory and reassurance oriented behaviors.

According to Turvey, (1999) "There is a lot of passive anger evidenced in these crimes, and other behaviors speak to a lot of inadequacy on the part of the offender." Key behaviors included:


Example #1: As an example of a psychopathic sadist, Cleckley, (1988) presents the case of Neville G.C. Heath. At the time of his arrest in 1946, Heath was a 29-year-old former Royal Air Force officer that had been court-martialed in 1941 for charges related to fraud and being absent without leave. His personality was described as charming, profoundly sincere, irresistible to women, and as having the ability to impress others easily as a man of wealth and intelligence.

On Friday, June 21st, 1946, the dead body of 32-year-old film extra Margery Gardner was found in Room No. 4 of Pembridge Court Hotel in Notting Hill, London. Her ankles were bound with a handkerchief. Additionally, her nipples had been bitten off, and there were many whip marks on her back, chest, stomach and face. The forensic pathologist, Dr. Keith Simpson, determined that she had suffocated, either from a gag or from having her face pressed into a pillow. The room her body was found in was registered to Mr. and Mrs. N.G.C. Heath.

On July 6th, 1946, the dead body of 21-year-old Doreen Marshall, formerly of the Women's Royal Naval Service, was found in Branksome Chine. She was discovered in some rhododendron bushes, naked with the exception of her left shoe. Her clothing had been placed on top of her. Prior to her death, Heath had bound her hands, which bore defensive cut marks suggesting that she tried to resist a knife attack. She died of exsanguination, after having her throat cut.

Heath was only charged with the murder of Margery Gardner, but the details of the Doreen Marshall killing were allowed into evidence. Though his lawyers tried to plead Heath's insanity, the jury found him guilty on September 24, 1946. He was executed by hanging one month later.

According to Cleckley, (1988):

"Each of the two young women tortured and killed by Heath within a period of three weeks was cruelly butchered. The sexually sadistic quality of Heath's behavior on these two occasions is made plain by the nature of the mutilations. A nipple was bitten entirely from one girl's breast… With the other girl, this had almost been accomplished. At the autopsy both showed that some instrument, perhaps a poker, had been thrust with violence into the vagina, rupturing it and damaging the abdominal viscera. In one of the victims the poker had apparently been driven far up into the abdominal cavity and twisted about with great violence. One body had been lashed severely by a heavy, metal-tipped whip… The abdomen of one woman had been ripped open so extensively that the intestines emerged and spread sickeningly over the area about her body. One deep gash started below the genital organs and extended up into the breast…

The victims were tightly bound and gagged. Points brought out at the autopsies indicate the Heath wanted the women to remain alive as long as possible to experience the agony resulting from his vicious torture and that he seemed to relish the butchery, particularly while the victims still remained conscious and capable of feeling it. Apparently, he also found perverse sexual satisfaction in continuing after death the gruesome and protracted mutilation of the bodies."

Many of the offense behaviors related in this account, in context, are arguably sadistic. These include whipping the victims, binding their limbs, gagging their mouths, any premortem insertion of items into the vagina (with violent twisting), any premortem mutilation with the knife, and any premortem biting of the victims' breasts. However, not everything that a sadist does is sadistic. Any postmortem acts committed by the offender (i.e.- cutting or mutilating), though perhaps sexually motivated, could not have induced the requisite victim suffering and should not be described as sadistic.

Example #2: As an example of a sadistic offender Burgess, Groth, Holmstrom, and Sgroi, (1978) present the case of "Paul," a single, white, 19 year old male who was convicted of four rapes, but later admitted to over twenty. According to his account, he would typically select an innocent looking girl, around the age of 12 and force her into the woods with a knife. He further related the following:

"Then I'd give her a choice: I would rape her or cut off her hair. I'd tie her hands behind her back with my belt, put the point of my knife between her eyes, and threaten to kill her. Then I'd get undressed and make her lick my body and blow me because I knew she wouldn't want to do it. I'd get all shaky and excited. I would keep her scared and frightened-- her fear and suffering gave me pleasure. Sometimes while the girl was blowing me I'd burn her with a cigarette on her shoulder and ass and 'come off' in her mouth, sometimes I would punch her and stomp on her hand with my workboots… Even now when I think about a girl getting beat up, or see it on television, I get a 'hard-on.'"

All of the offense behaviors related in this account, in context, are arguably sadistic. Aggression and violence are in the service of increasing sexual gratification. Note, however, the absence of homicide. As discussed, sadistic behavior does not necessarily result in a homicidal act.


Generalized Behavioral Assumptions

In the process of reviewing the literature, it became evident that many authors were in the practice of advocating that certain behaviors were always sadistic in their nature, despite their context. This by virtue of their own experiences of behavioral associations in case work, or more often by reasoning that for certain behaviors one can assume extended victim suffering, and assume that the offender's motive and intent was to inflict and enjoy that suffering to service sexual gratification.

Either practice introduces generalized and potentially inaccurate behavioral assumptions into the motivational analysis of individual offender behavioral patterns. As already discussed, unless a behavior is intentionally inflicted to a living, conscious victim for the purpose of achieving sexual gratification, it cannot begin to meet the burden required by sadism. Broad generalizations regarding the motivations of a single behavior across multiple offenders, based on the motives of other offenders, deprives individual behaviors of their context, and subsequent meaning (Turvey, 1999).

The inference of offender motivation from physical evidence of behavior, and behavioral patterns, for investigative or courtroom purposes, is an expedition into the realm of forensic examination regardless of the professional involved. Forensic examination is about the exploration of possibility. Until proper forensic tests and analysis have been undertaken, and the context of the offense behaviors narrowed by virtue of crime reconstruction efforts, those possibilities cannot be reliably inferred.

More to the point, a forensic examiner can only form opinions regarding those behavioral elements of an offense for which there is physical and behavioral evidence. Consider the following examples from the literature:

Rape: The generic term "rape" is not a specific behavior, but rather a penal classification that represents the occurrence of a variety of potential offender behaviors. These can include, depending upon the laws of the region, forcible penetration of a victim's vagina with a foreign object, forcible penetration of the victim's mouth with a penis, and/or forcible penetration of a victim's anus with a finger. Accordingly, when used as the only descriptor of an offender's behavior this term has limited behavioral meaning.

Knight, Lee, Prentky, and Rosenburg (1988), Hazelwood, Reboussin, Warren, and Wright (1991), and Turvey (1999) agree, based upon initial studies conducted by Groth (1979) and continued research efforts, that the psychological needs satisfied by rapist behavior can be described by four general categories:

As to the sadistic aspect of any rape behavior in general, however, Dietz et al (1995), argue that:

"Rapists cause their victim's to suffer, buy only sexual sadists intentionally inflict that suffering, whether physical or psychological, to enhance their own arousal."

If the acts involved in a particular rape (i.e.- some kind of forced penetration) are used as torture, over time, to humiliate the victim and cause suffering specifically to sexually arouse the offender, then a reasonable argument for their classification as sadistic can be made. In the absence of these types of acts, other psychological needs may be at work. Therefore, it is the duty of the forensic examiner to analyze the established patterns of behavior in a particular case, and form opinions about the nature of individual behaviors within the context of those patterns.

Anal Assault: Anal assault is a term that may refer, generally, to any physical attack of the anus. Some examiners consider this behavior sadistic in any context because it involves the infliction of pain to a victim associated with a sexual act. Such an interpretation also assumes the intent of an offender to inflict suffering.

It is certainly true that some offenders insert objects into a victim's rectum in order to witness their subsequent suffering for the purposes of servicing their own sexual gratification. This could be described accurately as a sadistic behavior. However, some offenders force objects into victim orifices, including the anus, either premortem to service anger-retaliatory motivations, or postmortem to service fantasy based reassurance oriented motivations.

Dietz et al (1995) argues that when a victim is anally assaulted, there is not necessarily one explanation for that behavior. Rather, there are other possibilities:

"Anal assault is an example of a sexual act that often has underlying motivation. When anal sex has taken place in a nonconsensual relationship, the authors consider four possible reasons: acting out a fantasy and/or latent homosexuality; sexual experimentation; to punish, degrade, and humiliate; or the behavior of a former convict."

This explanation, however, is potentially confusing because it suggests that examiners place the behavior in one of the finite categories, almost a checklist, without fully explaining the psychological needs inherent in them, per Knight et al (1988), Hazelwood et al (1991), and Turvey (1999). In fact, this checklist of reasoning might mislead examiners to place an act of anal rape that is motivated by either sadistic or retaliatory needs into the same broadly defined punishment oriented category. This could have the effect of causing an examiner to fail to recognize the possibility of sadistically motivated anal rape.

Example: Krafft-Ebing (1898), adduces case no. 216, that of a "Lustmurder," involving a 19 year old male laborer referred to as "K." who killed a 10 year old girl named Anna:

"…her body was found about fifty paces from the main road, in a copse. The face was turned to the ground; the mouth was gagged with moss; signs of a criminal assault about the anus…

K. was arrested. At first he denied the deed; but afterwards made a complete confession. He had strangled the child, and when she stopped kicking and resisting, committed sodomy upon her."

In this case the anal rape, referred to here by the general term sodomy, occurred after the child was unconscious, possibly even after the child was deceased. In either case, the burden for sadism is not met. The anal rape behavior described in this case arguably falls more within the parameters of reassurance-oriented.

Strangulation: Both manual and ligature strangulation involve the restriction of oxygenated blood to a victim's brain by compressing the arteries in the neck. It is true the some offenders engage in the practice in order to bring the victim in and out of consciousness, achieving sexual gratification from the victim's intermittent suffering responses. This could be described accurately as a sadistic behavior. However, some offenders employ strangulation in their offense behavior not for fantasy, but for function. Manual and ligature strangulation may be used in the process of subduing, controlling, punishing or killing a victim separate from sadistic motivations.

Example: Krafft-Ebing (1898), adduces case no. 18, that of a "Lustmurder," involving a 26 year old homeless man named Vacher who was found "guilty of eleven murders, which are acts of sadism, Lustmurder. They consisted of strangling, cutting of the throat and ripping open of the abdomen, mutilation of the corpse, especially the genitals, eventually gratification of the sexual lust on the corpse."

In this example, sadism is also attributed to the overall aspect of the crimes by the author. Paradoxically, the majority of the acts committed on the victim were postmortem. Strangulation was Vacher's method of killing, but there is no evidence, as argued, that killing the victims was anything other than functional. That is to say, the offender could not engage in his preferred behaviors (postmortem mutilation) with a living, conscious victim and sexual gratification was not associated with any premortem activity. The behavior in this case, as argued by Krafft-Ebing (1898), does not meet the burden required for use of the term sadistic.

Biting: Brittain (1970), while widely referenced in the literature does not give a specific operational definition of sadistic behavior in his opinion piece on the topic. He does remark of biting that:

"Bitemarks may be found and are most commonly on the breasts or neck of the victim but they are not restricted to these sites. They can vary from being minor to being very severe. They can occur in homosexual as well as heterosexual sadistic murders."

It should be noted that this vague behavioral discussion is representative of Brittain's overall approach to the topic of sadism. He first adduces examples of behaviors that might be sadistic, but then fails to define specific contexts in which sadism is a certainty.

Some offenders bite their victims, leaving visible and identifiable bitemarks on the surface of the skin and in the tissue beneath. Geberth (1996) discusses three possibilities motivating the infliction of bitemarks:

Therefore, while biting can be a sadistic act, it is not necessarily so. Any sadistic motivation associated with biting behavior must be established, and cannot be assumed.

Killing the Victim: Some offenders kill their victims. However the act of killing is not evidence, by itself, of sadism. Firstly, there must be victim suffering. Even still, victim suffering may be ancillary to an offender's purpose. There must, again, be evidence of offender sexual gratification from that suffering. Sadists, arguably, would want to keep their victims alive and conscious as long as possible in order to continue their gratification from that suffering. The earlier on in the offense a victim is killed, the less likely it is that there would have been an opportunity for sadistic behavior.

Killing a Victim in Front of Another Victim: As discussed in the previous example, some offenders kill their victims. However the act of killing is not evidence, by itself, of sadism. Nor is the act of killing one victim in the presence of another inherently sadistic. As one possibility among many, homicide may be precautionary in nature, simply to rid the offender of a living witness. In such a case, any suffering or trauma experienced on the part of the second living, conscious victim is ancillary to the offender's motives. As another possibility, homicide may be retaliatory in nature, done in the presence of living victims who witness the act but are not the object of the offender's rage.

Postmortem Mutilation: Postmortem mutilation to a victim is perhaps the one behavior that is most consistently, and quite erroneously, argued as sadistic in nature. As already discussed, this is likely in no small part due to the confusion in the literature between Lustmurder and sadism. For example, one clinician (Simon, 1996) describing sadistic behavior argues:

"Serial sexual killers are always sadistic, sometimes necrophilic, often both. They all obtain sexual thrills from the hurt and terror they produce in their victims, and from the total power they wield over their victims, alive or dead."

Aside from being a broad generalization that does not hold true when applied to known serial murder cases, this statement suggests that sadistic behavior can include power exercised over a dead, non-responsive victim. As already discussed, by definition unconscious or deceased victims cannot give a sadist the type of feedback required for sexual arousal (i.e.- crying, screaming, begging, whimpering, struggling, etc.).Therefore, postmortem acts (such as necrophilia), or acts committed on an unconscious victim, cannot be accurately described as sadistic.

Example: Bain et al (1988) adduces the case of an alleged sadist, Mr. A, who "murdered a woman and had intercourse with the corpse. He then removed the genitals and was contemplating eating them when he was interrupted by a third party and fled the scene of his crime." The behavior in this case, as argued by Bain et al (1988), does not meet the burden required for use of the term sadistic.

Example: Holmes (1991) defines necrosadism as "interest in having sex with dead bodies; necrosadistic killers murder to have sex with the dead." This term is, for lack of a better word, an oxymoron. The dead cannot suffer. Sadism requires victim suffering. Therefore, this term is not only inappropriate but it is misleading.

Expressing "Sadistic" Tendencies in a Post-Offense Interview: Many authors base their interpretations of sadistic offense behaviors on statements made by an offender during post-offense interviews. Clinical training and experience interviewing sex offenders aside, there are a number of practical reasons why the results of any post-offense offender interviews should not be taken at face value. According to Abel (1990), in cases where parole is a possibility:

"To be forthright and honest about the number of his sex crimes, or the degree to which he used force and violence during his assaults, may severely jeopardize the offender's opportunity to leave prison and might extend his incarceration should he be found guilty of new sex crimes that were revealed during questioning."

However, in cases where parole is not a possibility, there are equally compelling reasons for an offender to deceive interviewers about the nature and extent of their criminal behavior. These include the following:



After a thorough examination of the publications referenced in this literature review, the authors have formed several conclusions relevant to forensic casework.

Firstly, and perhaps most importantly, the term "sadistic" is not consistently applied within the literature by investigators, criminologists, or those in the treatment community. Moreover, it is often vaguely defined and broadly employed.

Secondly, there appears to emerge from the literature two common types of misinterpretation:

  1. Punishment and anger motivated behaviors misinterpreted as sadistic
  2. Postmortem necrophilic or mutilation behaviors misinterpreted as sadistic

The second type of misinterpretation may be occurring in some instances based on examiner assumptions that offender mutilation is always premortem. This assumption, which appeared to occur numerous times in the literature, may suggest a lack of reliance on competently, objectively reconstructed offender behavior when forensic opinions are being formed. That is to say, examiners may assume behaviors, which are not being established by the physical evidence, for the purposes of forming opinions regarding offender sadism. This practice is not justifiable.

Thirdly, there were a number of authors (De Burger et al, 1988; Geberth, 1991; Geberth, 1996; Geberth et al, 1997; Holmes, 1991, Holmes, 1996) who consistently referenced fictionalized and sensationalized "true crime" novels as primary source material for their research regarding specific offender behaviors. This practice undermines the credibility of accounts given in legitimate research, raising issues of reliability and objectivity. Most disturbing is a practice in the professional community where some adopt as fact the sensationalized, fictionalized reconstructions of offenses by "true crime" authors as proper data for study.

Finally, in reference to those offenses described as sadistic or "Lustmurder," the authors noted frequent and liberal use of relative moral descriptors. In fact, some authors have devoted sections of their professional work to discussing the moral disposition of particular offender types, and, as evidenced by excerpts in this paper, frequently use such subjective and relative terms as:

These subjective terms and moral positions form the basis for emotional arguments, as opposed to logical ones. Their meaning is furthermore culturally subjective. Therefore, while they do give readers insight into the personal belief system of the authors who use them, they arguably act as a very tangible barrier between researchers and their understanding of individual offender motivations. The use of such terms does not advance the cause of objective research.


Future Concerns

After a careful consideration of the above conclusions, the authors perceive a number of concerns regarding the application of the term "sadistic" in non-treatment oriented forensic case work. It is possible that the broadly defined and overly applied definitions of sadism that are at work in the literature may have effected or even skewed the results of research into serial murders, serial rapists, and sexual sadists.

For example, a questionnaire based study by Feister, Gay, Pfohl, and Spitzer (1991) found that approximately 50% of clinicians surveyed had, at some time, evaluated in a forensic setting, a subject who exhibited behavior that met the criteria for sadistic personality disorder. One of the conclusions of that study was that the diagnosis of sadistic personality disorder in forensic settings is probably not a rare occurrence. However the conclusions reached in this work could suggest that increased reporting of cases involving sadism might very possibly be attributed to a lack of understanding of the term.

Additionally, an extensive study by Bradford and Gratzer (1995), compared the offender and offense characteristics of 30 sexually sadistic criminals studied by Dietz et al (1990) with those of 29 sexually sadistic criminals and 28 nonsadistic sexual offenders from the Royal Ottawa Hospital. Some of the findings in this study were skewed because, as Bradford et al (1995) explains:

"Deitz et al excluded individuals who rendered the victims unconscious by asphyxiation, before physically assaulting them. On the other hand, we included these individuals (that is, offenders who physically assaulted unconscious victims) because in our opinion, both the act of rendering the victim unconscious and the subsequent physical assault of the victim reflect sadistic tendencies. Asphyxiation, as a method of torture, may be associated with sexual sadism because it enables the offender to exert greater control and power over the victim."

Bradford et al (1995) included in their sample offenders who might be sadistic as opposed to those who actually evidenced clear, unambiguous sadistic behavior.

In any case, though perhaps appropriate for studies related to treatment issues only, the main concern is that the results of such studies will find their way into courtroom opinions where the standard for establishing sadism is necessarily higher. Given the investigative use of sadism as a signature aspect, evidenced by particular signature behaviors (Hazelwood et al, 1991; Geberth, 1996; and Turvey, 1999), to link cases and understand offender motivations, the potential for investigative misdirection is also great.

The conclusions in this literature review also call into question serial murder research, which covers sadistic components. The implications of such vague and broadly applied definitions become particularly disturbing when considered along with the proposal and/or adoption of broadly inclusive "sexual predator" and "serial killer" statutes by heavily populated, high crime states including California, New York, and Texas. The implications are equally disturbing in those states where torture, or other sadistic behaviors, may be considered as aggravating factors in capital sentencing, including California, Georgia, Mississippi, Texas, and Washington. When such statutes are invoked, defendants may be deprived of due process by experts who give testimony on the issue of serial murder, torture, or sadism based on vague definitions, incorrect behavioral assumptions, and uninformed predictions. Further still, given attempts to associate sadism with recidivism (Quinsey and Chaplin 1988), the issue of civil commitments, as raised in Kansas v. Hendricks, Case No. 95-1649, may also be cause for concern.

As stated by Brittain (1970) in his opinion piece on the subject of sadism:

"In conclusion, it should be said that to write such material in our present state of knowledge except for those legitimately concerned in a medical, legal, or criminological journal would be to render society a disservice."

This conclusion was drawn nearly three decades ago, and arguably the literature has matured little since. In fact, there is strong evidence to suggest that it has actually regressed.


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