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In my last blog post, I wrote about the ongoing investigation into Chad Daybell and Lori Vallow. Lori is currently sitting in an Idaho jail facing charges of felony child abandonment and desertion of two of her children, 7-year-old JJ and 17-year-old Tylee, who have not been seen since September 2019 despite pleas from concerned family members and a court order demanding Lori produce them.
Amid allegations of a doomsday cult, spiritual prophecies, and beliefs in zombies and teleportation, the mysterious deaths of three adults are also tied to Lori and Chad, including the deaths of the couples’ former spouses over the past year followed by their marriage shortly thereafter.
Did Lori’s alleged belief that her children had been taken over her missing children’s bodies have anything to do with their disappearance? Did Chad Daybell’s assertion that his former wife of 30 years, Tammy, wasn’t one of the 144,000 chosen ones to survive the upcoming July 2020 apocalypse (not to mention his “spiritual premonitions” of her upcoming demise) play a role in her death?
At present, it is unclear to what extent these religious beliefs have played in any of these events. But, if they did, could they be grounds for an insanity defense?
What Does It Take to Be Insane?
On Monday, March 23, 2020, the U.S. Supreme Court ruled that individual states could abolish the insanity defense. As a result, whether or not a person is legally insane now depends on the state in which the crime is committed.
Lori Vallow and her new husband Chad Daybell are now being investigated by the Idaho Attorney General’s Office in connection with possible conspiracy and either murder or attempted murder in the death of Tammy Daybell. Idaho is one of four states that no longer allow an insanity defense; psychotic defendants typically plead guilty to lesser charges and rely on judges to take mental health into account at sentencing.
Tylee Ryan, Lori Vallow Daybell’s missing 17-year-old daughter, was last seen during a day trip to Yellowstone National Park, a park that spans Idaho, Wyoming, and Montana. Ninety-six percent of Yellowstone is in Wyoming, which follows the Model Penal Code Test. So what would this mean if Tylee Ryan met with foul play in Wyoming and the person charged with the crime claimed s/he was insane at the time?
A criminal defendant who pleads NGRI in the state of Wyoming would have to be formally diagnosed with a mental defect (typically by a court-appointed mental health professional); most successful NGRI pleas involve a defendant with a long history of severe mental illness [and treatment] before the crime was committed. S/he would then have to show that either s/he did not know right from wrong [for example, believed s/he was committing a virtuous or heroic act] or lacked the ability to control an impulse that led to the incident [for instance, acted on a command auditory hallucination that gave him or her specific instructions at the moment].
Arizona is another state in which Lori Vallow Daybell is under suspicion, this time for the death of her former husband, Charles Vallow. In Arizona, a defendant cannot be found not guilty simply because they make a plea of insanity. Instead, a severely mentally ill defendant can be found “guilty except insane” if it can be shown that “at the time of the commission of the criminal act the person was afflicted with a mental disease or defect (for example, post-traumatic stress disorder, bipolar disorder, major depression, or schizophrenia) of such severity that the person did not know the criminal act was wrong. It excludes “temporary conditions arising from the pressure of the circumstances, moral decadence, depravity or passion growing out of anger, jealousy, revenge, hatred or other motives in a person who does not suffer from a mental disease or defect.”
But what about cults? Can cult-induced beliefs be psychotic?
Just Because Beliefs Are Strange Doesn’t Mean They’re “Crazy”
Cults are generally defined as new charismatic groups that tout a religious doctrine that appears unusual or even bizarre to those outside of the group. As such, almost by definition, it is difficult for an outsider to tell whether a belief is based on the teachings of the cult leader or the delusions of the follower. When a cult member is charged with a violent crime, this distinction may be the difference between a valid insanity plea and a guilty verdict.
In 2016, researchers identified 398 cases in which murder was committed either because of a cult leader’s directive or because of the cult’s alleged beliefs. However, an insanity plea was a rare choice for cult members who were criminal defendants; only 8 out of the 398 original cases, either as an original defense or as grounds for an appeal [the failure of the original defense to plead NGRI]. This was true even when an insanity defense appeared to be the best option.
For instance, given the level of mind control by drugs, violence, and fear that Charles Manson exerted on his followers, an NGRI plea would seem an obvious choice for the “family members” who were charged with murder. And yet, not a single Manson follower pleaded NGRI. Perhaps the same devotion that persuades cult members to commit violence for their leader also clouds their judgment when it comes to defending themselves in court.
But a few cult leaders and followers have tried it; none have been successful. In 1985, Michael Ryan, the leader of a cult that embraced Anglo-Saxon supremacy, the unconstitutionality of income taxes, and the upcoming Battle of Armageddon, was accused of murdering one of his followers, James Thimm. Mr. Ryan did not dispute this but claimed it was under the specific instruction of his God Yahweh, an order he was spiritually obligated to obey. However, he ultimately changed his tune and pleaded Not Guilty by Reason of Insanity.
Both defense mental health experts found him to be psychotic at the time the crime was committed; one diagnosed him with paranoid schizophrenia. The prosecution’s experts, however, did not believe Mr. Ryan had a psychotic disorder. The jury agreed, concluding that the pursuit of fanatical religious beliefs did not mean that a person did not know the difference between right and wrong. In fact, courts have not considered cult beliefs to be delusional, regardless of how bizarre they seem or how disastrous their results.
Cults Are a Choice
American courts ultimately view cult beliefs—even those that have driven people to murder—as voluntary. A forensic expert must attempt to distinguish the defendant’s beliefs from those of the cult to determine if there is a psychosis lurking underneath. If the defendant’s criminal behavior stems solely from the cult doctrine, the court may reject them as evidence of mental illness. No one should be able to avoid responsibility for criminal conduct in the name of religion.
If you'd like more forensic psychology information, check out my website, forensic radio show, and YouTube channel.
