"Brainwashing" and Cultural Diffusion

The term brainwashing nearly always refers to some process of recruitment or resocialization and has a quite negative connotation. The brainwashing idea has become rather pervasive within the United States, with the term now being used in many different contexts, including the legal one. This brief review has shown that the brainwashing notion has been involved in many different types of actions within the American legal system. Usually the side in a legal dispute presenting brainwashing-based claims wins, especially when to accept the claims means that juries and judges can "send a message" about their displeasure with "cults." (52) Thus, the past two or three decades have seen the development of a very powerful "social weapon" to use against unpopular groups (both political and religious) within America. (53)

Given the usual effectiveness of brainwashing claims, as outlined above, it is no surprise that the idea has become a much exported social and cultural product, with the concept appearing of late in a number of different legal and social/political settings outside the United States. (54) This section will examine a few of the cases in foreign countries involving the idea that new religions brainwash their participants.

The European Court of Human Rights

I will begin with a brief discussion of a major case decided in 1993 by the European Court of Human Rights. This case is important because it represents the only time since the court's inception in the 1950s that it has found a violation of Article 9 of the European Convention on Human Rights, which guarantees freedom of religion (including the right to change one's religion). The case, Kokkinakis v. Greece, (55) developed when a Greek Jehovah's Witness minister and his wife visited the wife of the local cantor. Mr. Kokkinakis and his wife attempted to proselytize the cantor's wife, which violated a Greek law precluding proselytizing activities. (56) The cantor complained, leading to the arrest of Kokkinakis and his wife, with both being charged with violating the criminal statute against proselytizing. Both were found guilty, fined, and sentenced to prison. On appeal, the charges against Mrs. Kokkinakis were dropped, but those against Mr. Kokkinakis were upheld.

The case was then appealed to the European Court of Human Rights in Strasbourg, which is the judicial arm of the Council of Europe. The court has a dismal record of supporting claims that religious freedom has been violated, and prior to Kokkinakis, there had never been a ruling that a violation of Article 9 had occurred. The usual tactic had been to dismiss such claims and defer to the Member States on such matters. (57) The court took more than five years to eventually rule in favor of Mr. Kokkinakis, but it did so only on a split vote of six to three, with some strong dissents registered. (58)

Of importance to this examination of the use of brainwashing ideas in legal actions outside the United States is the casual use of the term in the Kokkinakis opinions. Both the majority and one dissenting opinion make use of the term, as well as other .associated "anticult" terminology such as "unacceptable psychological techniques." (59) The majority opinion included the language, "I would add that there probably are methods of spiritual coercion akin to brainwashing which arguably fall within the ambit of Article 3 of the Convention and should therefore be prohibited by making their use an offense under ordinary criminal law." (60) Some of the judges were apparently upset at the rigorous recruitment tactics of the Witnesses, seeming to assume that such strong efforts at recruitment were unacceptable because they involved brainwashing, thus placing them beyond the pale of protected activities. The appearance of such language in a major written opinion of the Court of Human Rights is evidence that such ideas have gained credence within that forum. (61)

Brainwashing Cases in Spain

Spain has seen anticult (or antisect) activity develop over recent years. In the late 1980s, state officials showed considerable animosity toward representatives of one controversial new religious group from the United States, The Family, formerly known as the Children of God. The growing concern about The Family culminated in raids on Family communal homes and the confiscation of children from their parents in attempts to make them wards of the state. It is now clear that this and similar cases around the world were given impetus by the actions of a few former members and other detractors who worked hard to develop concern among law enforcement and legal officials. (62) The focus of this effort to arouse official concern was on child abuse allegations, including sexual abuse. However, discussion of the case within Spain also made reference to how controversial the group was, in part because of its suspect recruitment methods, which were sometimes referred to as "brainwashing." Although resolution of the matter took some time, The Family eventually prevailed and regained custody of their children after it was proved to the satisfaction of authorities that no abuse was occurring within the group.

More recently there has been a case directly involving brainwashing claims in Spain. In February 1996, a decision was handed down resolving a legal dispute concerning a member of the Spanish Society for the Defense of Tradition, Family, and Property ("TFP"), a Spanish branch of a controversial Catholic inspirational group operating in Spain since 1971. (63) The member, Santiago Canals Coma, was a twenty-six-year-old man whose mother decided to extract him from the group through deprogramming after she became convinced that the group had "brainwashed" her son. She apparently developed this belief in brainwashing theory through contact with a number of people opposed to the group, including an antisect group operating in Spain, called Centro de Recuperacion, Orientacion y Asistencia a los Afectados por las Sextas (Center for Recuperation, Orientation, and Assistance to Those Affected by Sects). This group apparently furnished the two deprogrammers who worked on Coma while he was incarcerated against his will in a mental institution.

The case involved a psychiatrist who, without benefit of an examination, made an assessment of Coma as being in a "paranoid state" and recommended internment in a mental institution. Police authorities enforced this recommendation, placing Coma in an institution where he spent twenty-two days before being liberated by a friend he finally managed to contact, who was also an attorney. While there, Coma was drugged, forced to exist with very few clothes, and kept in a locked room. He was visited regularly by deprogrammers, who ordered the hospital staff not to allow him any contact with outsiders.

After being freed from the mental institution, Coma still had to deal with legal actions filed by his mother, seeking to continue the incarceration and also to have Coma declared mentally incompetent. The case eventually went to trial, and considerable testimony and affidavits were filed by conflicting experts and others, including several family members. On February 9, 1996, Magistrate Maria del Mar Ortega Arias issued a lengthy and strongly worded ruling against Mrs. Coma and in favor of her son. (64) This ruling represents one of the few times outside the United States that brainwashing claims have been explicitly discussed in any detail, and therefore the ruling deserves some attention.

After recounting the facts of the case, Magistrate Arias stated: "On the pretext of a clearly nonexistent mental illness an adult citizen was deprived of liberty solely for his religious beliefs, and an attempt was made to give this the appearance of legality, [which] constitutes a patent abuse of law that this judge wishes to make especially evident." (65) The judge further stated that she must discuss matters usually not included in judgments because

[it is] evident that Mr. Santiago Canals Coma does not suffer from any type of mental illness that would justify his wrongly claimed incapacitation, [and to] guarantee his right to religious freedom, which is enshrined not only in article 16 of the Constitution but also very especially in article 9 of the European Convention on Human Rights. (66)

Later in the opinion, the judge was explicitly critical of the extensive testimony of one leader of an antisect movement in Spain which had circulated literature claiming that TFP engages in "brainwashing of ... children." (67) The judge also took to task the petitioner (Mr. Coma's mother) who claimed in documents filed with the court that TFP is "a destructive sect that brainwashes its members." (68) The judge cited a letter, written by a Cardinal Ruiz and entered into evidence by the defendant, Mr. Coma, which refutes the claim "that TFP is a cult, that something like brainwashing exists, or that in TFP there are deviations from the true worship." (69) She also cited another report referring to the "old, worn-out accusation of brainwashing."

The judge then offered her own views and conclusions regarding use of such key terms as brainwashing: (70)

It is also pertinent to cover ... another term widely used by the petitioner: "brainwashing." The term does not express a scientific concept, but its meanings are many. It has been used at times as a synonym for "mental control,' to designate any form of human influence, including hypnosis, psychotherapy, mass media, propaganda, education, behavioral changes, and a constellation of other technical forms for changes in attitude and behavior.

It is necessary to be very cautious about this concept of "brainwashing," since man is a rational being who builds and structures his thought starting from freely accepted truths, on which he normally bases his values, and therefore those convictions can only be changed by appealing to reason. Consequently the concept of "brainwashing" is meaningless, especially juridically: its "indiscriminate" or 'careless" use may result in a clear meddling in extremely personal rights of the individual, which nobody may impinge. (71)

This judgment is a strong statement rejecting brainwashing claims in a court ruling outside of the United States. The total rejection of the use of the term "brainwashing" and its attendant ideas does not, of course, mean that the ideas themselves will cease to be used in policy debates about new religions in Spain. Indeed, if the United States experience is any guide, it is clear that negative views of new religious groups and their recruitment practices will continue to be very persistent. However, at least in Spain there is one opinion (admittedly from a lower court) that stands in opposition to the use of such ideas.

Argentina Brainwashing Case

Argentina has also seen the use of brainwashing claims in legal actions against The Family. In 1989, a large number of police, motivated by accusations of child abuse, including sexual abuse, staged a raid on a communal home of The Family in Buenos Aires. Adults in the commune were taken into custody, and children were placed as wards of the state. Some of the police carried machine guns during the raid, which was carried out without any warning but with electronic and print media representatives present.

Investigations by social workers and physicians revealed no evidence of sexual abuse or abuse of any kind. The children passed educational tests with high scores, impressing judicial authorities and teachers administering the tests. Officials of the court who visited the home after the raid went away impressed with the atmosphere of the home and the way the children were being educated. As a result of the testing and investigations, all criminal and civil charges were eventually dropped against the group and its members. The children were returned to their parents and the authorities made positive statements about the group and its child-rearing methods.

However, on September 1, 1993, police in Buenos Aires again raided several residences of The Family, taking 137 children into custody and arresting 21 adults. The raids were apparently instigated by one particular magistrate who had become convinced through the efforts of some former members of the Children Of God from outside the country that great abuses were taking place in Family communal homes. The episode became something of an international incident, as members of The Family throughout the world demonstrated at a large number of Argentine embassies in other countries and otherwise attempted to draw attention to the plight of their imprisoned members. A number of scholars and other professionals also offered support for The Family, writing letters of support and criticism of Argentine officials and visiting Argentina to investigate the situation.

The outcome was similar to that of the earlier episode. On December 13, 1993, the Argentina Court of Appeals of San Martin ordered the dropping of all charges, the release of all imprisoned members of The Family, and the return of all children to their parents forthwith. (72) The lengthy two-to-one opinion by Justice Horacio Enrique Prack strongly criticized the magistrate and also those from outside Argentina who were promoting such charges against The Family. The opinion also contained an explicit discussion of brainwashing claims, which had been presented by the group's detractors as part of their effort to force the authorities to take action against the group.

In discussing charges against Family members under something called the "servitude offense," which apparently means that a person is forced against his or her will to take part in activities directed by another, the court stated that the District Attorney

thinks that such a submissive attitude is reached through the application of a novel technique known as "thought reform" or "brainwashing", induced by deprivation of sleep, low-protein diets, exhaustive physical labor, long hours listening to "Mo's" recordings, reading and memorizing his letters, singing the groups' songs and participating in indoctrinational meetings, as well as through isolation and a loss of contact with the outside world, depriving the minors of any interchange with other children that they may become excessively dependent upon reaching adolescence so as to begin the practice of prostitution. (73)

The court then systematically discussed these elements, finding that few of them existed, and that those which did exist were relatively harmless in effect. (74) Later in the opinion, in discussing charges of false imprisonment, the court again referred to accusations of brainwashing that were brought against the group in earlier testimony by a few ex-members. (75) The court discussed the claim that false imprisonment can be brought about by

a sort of "psychological conditioning" which is mentioned by the Hon. District Attorney in specific reference to what various exmembers call 'brainwashing", accepting as fact that it is possible to modify a person's thoughts at will in order to oblige him/her to absolutely submit and relinquish his/her power of decision, a technique which they claimed they had been victims of. In fact, it does not seem quite logical to assert that through non-violent means-without resorting to confinement or torture-it is possible to apply various techniques, which could incur serious consequences for the person not in agreement, and succeed in doing so in the sense that the person changes his/her way of thinking and feeling. This is what happens in these fictional accounts, the magical contents of which amuse us as would a story describing automatons directed by remote control. (76)

The court goes on to say:

[I]n spite of efforts made during the Cold War by Communist countries in conflict-according to compiled information-no progress was made in the conversion of captured prisoners, even though they disposed of every means of coercive power. Therefore, this theory [of brainwashing] is not backed up by the scientific community and nowadays is considered as a metaphor to disqualify religious movements considered deviant. (77)

The court was then extremely critical of the Magistrate who accepted such a theory at the trial court level, calling the decision a judicial absurdity" which would cause "unacceptable consequences" because "it would lead to the inconsistency of having to declare innocent ... anyone acting in a manipulative manner, in spite of the fact that at the time of the crime he/she was capable of understanding the injustice of his/her actions." (78)

The court summarized its view of brainwashing and related claims as follows:

To claim that proselytism, even in the case of spreading immoral ideas, has become ideological subversion; that the initial persuading of someone to an exotic way of life, which is protected by the right to religious freedom, has become brainwashing; that missionaries have become subversive agents; that houses of spiritual retreat or monastic seclusion have become prisons; and finally, that mystical adherence to religious devotion has become psychopathic behavior, will undoubtedly bring us back to the time when society was authoritarian and repressed free thinking, limiting and castrating the freely chosen life style of each individual, simply because he/she preferred one over the other.

The problem of the new religious movements cannot be approached from a medical or criminological viewpoint, because in spite of the fact that we live in a time in which some new cults attract persons with physical and mental pathologies, and even some of their leaders use their charisma for financial ends, the very foundation of our legal system protects personal autonomy, and to impose limitations on the will is not possible, even if an individual is considered by others to be basically wrong. Nobody can be forced to be free. (79)

Justice Prack's strongly worded opinion has caused considerable consternation in Argentine legal circles. Currently the case is on appeal to the Argentina Supreme Court, which seems to be hesitant to deal with the decision. Meanwhile the original Magistrate in the case, in spite of being severely criticized in the appeals court opinion (or perhaps because of being so criticized), continues to be active in the case, a development that seems odd to those more used to American legal standards. (80) At present, he is summoning some of the twenty-one Family members charged in the case (who spent four months in prison) for further depositions. Thus, although the appeals court opinion very strongly rejects any criminal charges brought against Family members and also criticizes the ideological basis of the case ("brainwashing"), developments since the decision nearly three years ago indicate that antireligious sentiment and the ideas that underpin that sentiment have not died out in Argentina.

Brainwashing Claims in Australia

In May of 1992, simultaneous predawn raids were made against several communal homes of The Family in Australia, located in Melbourne and in Sydney. A total of 153 children were taken into custody, amidst an immense amount of publicity about accusations of aberrant sexual behavior in the group homes. The raids developed after lengthy investigations and surveillance of The Family homes in the two areas. Officials in Victoria decided to stage the raids when they did apparently because of a planned expose on The Family, which a popular TV program was planning to air. Officials feared that The Family would flee the area after the program aired. Victoria officials urged New South Wales child care officials to also participate, with less than forty-eight hours notice, by raiding Family homes there. It is noteworthy that in 'Victoria the television channel knew the timing of the raids and had cameras present, including some in helicopters flying above the homes being raided.

In Sydney (New South Wales) the case was resolved relatively quickly, after a lengthy hearing in which one representative of the Department of Community Services (the "DOCS") spent thirty-one days in the witness box trying to explain and defend why the DOCS had taken the action it did, but with relatively little success. Settlement was achieved after the DOCS agreed to a unique form of mediation with a former High Court judge serving as mediator. The settlement involved a withdrawal by the DOCS of official charges of sexual abuse, coupled with an agreement by The Family to allow some evaluation of the children's home schooling and to ensure the children had some exposure to people and activities outside the group.

In Melbourne (Victoria) the case took much longer to resolve, mainly because the state had refused to furnish legal aid to the group's parents, claiming funds were not available. Efforts had been made by The Family and its attorneys to settle the case similarly to what was done in New South Wales, but such moves were strongly resisted by the Child Services Victoria (the "CSV"), and a court-ordered effort at mediation failed. In the meantime, however, the ninety-three children involved in Melbourne were still technically wards of the state and could not be moved without permission from the court. Eventually the Victorian State Government forced the CSV to settle the case on terms quite similar to those developed in the Sydney case.

These cases resulted in a major embarrassment for most of the child services and police authorities involved in the predawn raids, and resulting legal actions against them by The Family continue even today. It is interesting to note that in a lengthy official explanation offered by CSV of its action, there is an explicit discussion of Robert J. Lifton's "thought reform" model (called "mind control" in the report) as a part of the justification for the actions taken by authorities. (81)

In the CSV report, under the subtitle "Rigorous Control over Disciples" there is a substantial discussion of the recruitment methods allegedly employed by the group, using Lifton's multistage model developed in his studies of how the Chinese Communists managed to gain the allegiance of the Chinese people after the takeover in 1950. The assumption of the CSV report is that this model has direct application to The Family and to other newer religious groups, including the Unification Church and Scientology. No critique is offered or referred to, and there is no explanation of the vastly different circumstances of recruitment in new religions, compared with the reeducation of Chinese under Communism. (82) The official document simply assumes that "mind control" methods are used by The Family, as well as other controversial groups, and that this helps justify the drastic action undertaken by the authorities.

Brainwashing Claims in Russia

There is much activity relevant to the topic of this Article taking place in Russia and other former Communist countries. Efforts to modify the Russian law passed in 1990 guaranteeing religious freedom may sometimes be based on claims that new and foreign religious groups are brainwashing their participants. This section examines one rather explicit example of the role of brainwashing claims to illustrate what can develop in the very volatile circumstances after the fall of Communism.

The situation that will be used as an example concerns the difficulties encountered by the Unification Church in St. Petersburg in its attempts to register with local authorities. When it became known that the Unification Church was attempting to become established in St. Petersburg, a number of individuals and groups took issue with those efforts. One of them, a group calling itself the Committee for the Protection of the Family and Individual, filed suit in a local court. The suit sought the liquidation of an ancillary organization of the Unification Church, an entity known around the world as CARP (Collegiate Association for Research into Principles), and asked for a large amount of compensation for "victims" of CARP. (83) Other groups and governmental officials have since joined the suit, including a group calling itself The Interregional Committee for the Salvation From Totalitarian Sects, as well as the Department of Justice of the St. Petersburg City Council and the Attorney General for the St. Petersburg area. The cases were consolidated, some parties were dropped by the court, and the suit was finally allowed to stand with two plaintiffs, the original committee and the Attorney General. (84)

CARP had been officially registered in St. Petersburg since December of 1991, but came under scrutiny as a part of the growing concern in Russia about the growth of new foreign religious organizations. Attempts by the Unification Church itself to register in St. Petersburg may have provoked the suit. Of interest here are some of the claims made in the pleadings. A major claim concerns the alleged use of "mind control" on CARP participants and the related assertion that the group causes

destruction of the psychological basis of personality, family, and society by imposing various artificial ethical requirements which are alien to the traditional psycho-social characteristics of Russia. Through limiting sleep and food and daily nonstop, monotonous activities, the psychic and physical health of CARP members deteriorates and their intellectual development is impaired. (85)

This set of claims sounds quite like other renditions of brainwashing-based ideas that have been spread around the globe in the past decade or so. (86) According to reports on the machinations of this case, discussions of the brainwashing/mind control idea have played a major part in court proceedings and informal discussions surrounding the case. Apparently the possibility for a resolution of the case that rejects such claims for being unscientific (as has happened in some other countries, as previously described) is slim. Instead, according to some observers of this case, the prognosis is grim, even though data to support such claims is weak or nonexistent. (87)

One related development is that the Unification Church has been refused registration in St. Petersburg, even though it has filed required documents and been waiting a considerable time. One reason being given for the delay in processing the registration application is the pending suit against CARP. (88)

Footnotes

Click on the footnote number to return to return to previous location.

52. The term "cult" has become a quite negatively connoted term in the United States, somewhat similar to the term "sect" within the European context. See generally Jane Dillon & James T. Richardson, The 'Cult' Concept: A Politics of representation Analysis, 3 SYZYGY: J. ALTERNATIVE RELIGION & CULTURE 185 (1994); James T. Richardson, Definitions of Cult. From Sociological-Technical to Popular-Negative, 34 REV. RELIGIOUS RES. 348 (1993).

53. For an excellent discussion of the idea of brainwashing accusations as a .social weapon," see Robbins et al., supra note 12.

54. The major vehicle for the spread of brainwashing claims has been the development of anticult movements and groups in a number of other countries around the world, often through "missionary" efforts of American anticult groups such as the Cult Awareness Network. See ANTICULT MOVEMENTS IN CROSS-CULTURAL PERSPECTIVE (Anson Shupe & David G. Bromley eds., 1994) (discussing international anticultism). For a related situation involving export of a negatively connoted idea from the United States to other countries, see James T. Richardson, The Social Construction of Satanism: Understanding an International Social Problem, AUSTL. J. SOC. ISSUES (forthcoming 1997).

55. 93 Eur. Ct. H.R. (Ser. A) (1993).

56. Id. at 260.

57. For a fuller discussion of the Kokkinakis case and operations of the European Court of Human Rights, including its propensity to defer to Member States in matters involving religion, see James T. Richardson, Minority Religions, Religious Freedom, and the New Pan-European Political and Judicial Institutions, 37 J. CHURCH & ST. 39, 47 (1995).

58. A few of the facts of @ case make the split vote rather curious. In spite of the fact that the Jehovah's Witnesses have existed in Greece since 1922 and are recognized as a religious group under other Greek laws, over 4400 Witnesses have been charged with violating the Greek criminal statute against proselytizing since the statute was enacted when democracy was reestablished in 1975. Of these cases, 1233 have been committed for trial and 208 have been found guilty. No other group has been charged with violating this statute in that same time period, a strong indication of discrimination against the Witnesses. For a comment on the unusual nature of Greece's proselytizing law, see Silvio Ferrari, The Emerging Pattern of Church and State in Western Europe: The Italian Model, 1995 B.Y.U. L. REV. 421, 425.

59. Kokkinakis, 93 Eur. Ct. H.R. at 17, 35-37.

60. Id. at 36.

61. Recently the author received some correspondence indicating the development of an anticult group operating in Greece. The correspondence refers to efforts to control groups which do psychological damage to the writers and their families. Such communications suggest that the writers assume such ideas are widely accepted and valid.

62. See Richardson, Social Control of New Religions, supra note 45 (discussing raids against Family communal homes in Argentina, Australia, Spain, and France, all of which were similarly motivated, and all of which eventually resulted in all charges being dropped and children being returned to Family members).

63. This saga is described in some detail in SANTIAGO C. COMA, A REBIRTH OF RELIGIOUS PERSECUTION IN SPAIN? (1996). The case is similar to the famous Shapiro case in the United States, which involved the Hare Krishna. The son of a prominent psychiatrist joined the Krishna, and then was kidnapped and placed in a mental institution by court order on the basis of an assessment rendered by a psychiatrist who had spent very little time with the son. Eventually the son was found competent and released, in large part because a number of mental health professionals refused to agree with the original diagnosis and stated in court that the son was quite competent. For a full discussion of the Shapiro case, see James T. Richardson, Mental Health of Cult Consumers: Legal and Scientific Controversy, in RELIGION AND MENTAL HEALTH (John F. Schumaker ed., 1992).

64. Judgment of Feb. 9, 1996, Juzgado de Primera Instancia No. 42 de Barcelona [Court of First Instance No. 42 of Barcelona] (Spain), translated and reprinted in COMA, supra note 63, app. 8, at 161.

65. COMA, supra note 63, at 163 (emphasis omitted).

66. Id.

67. Id. at 166.

68. Id. at 167 (emphasis omitted).

69. Id. (emphasis omitted).

70. She also discussed the term 'sect' at some length, rejecting its application in the present case, and making critical remarks about its use as a powerful negative label. Id. at 168.

71. Id. at 168-69 (emphasis omitted).

72. Judgment of Dec. 13, 1993, Cimara Federal de Apelaciones [Federal Court of Appeals], slip op. 63-64 (Arg.) (official translation).

73. Id. at 44-45.

74. Id. at 45-49.

75. Id. at 50-51.

76. Id. at 51.

77. Id. at 52 (citation emitted).

78. Id.

79. Id. at 55.

80. This apparently occurred because the Appeals Court sent the case to a provincial court (equivalent to a state court in the United States) for further proceedings, but that provincial court recused itself, which had the effect of automatically sending the case back to the original federal magistrate. That magistrate is under considerable pressure in Argentina, in large part because of @s handling of The Family's case. Indeed, on October 7, 1993, a group of 45 lawyers and former judges submitted a petition for his impeachment to the federal Congress in Argentina, and the impeachment matter is pending at the time of this writing.

81. See Children of God Hearing: Summary of Case on Behalf of Department of Health and Community Services, at 72-75 (Melbourne, Sept. 10, 1993) (available from CSV and on file with author). Lifton's work is often used as a basis for claims that brainwashing, or thought reform, as it is sometimes called, occurs in new religions. See generally LIMN, supra note 14. But for a critique of this usage of Lifton's work, see Anthony, supra note 1, at 296; and Richardson & Kilbourne, supra note 14.

82. See James T. Richardson et al., Thought Reform and the Jesus Movement, 4 YOUTH & SOC`Y 185 (1972) (discussing an explicit application quite germane to the CSV claims of applicability of the Lifton model, namely a study showing the lack of support for applying the model to Jesus Movement groups, of which The Family is a prominent example). See generally BARKER, supra note 31; Anthony, supra note 1; Gene G. James, Brainwashing: The Myth and the Actuality, 61 THOUGHT: A REVIEW OF CULTURE AND IDEA 241 (1986); Richardson & Kilbourne, supra note 14.

83. Questions have been raised by the Unification Church about the standing of the committee to file such an action, but so far the action has been allowed.

84. The case, which has changed name and reference date several times, is now officially called The Claim of the Committee for the Protection of the Family and Individual for Liquidation of the CARP and Compensation for the Damage of 20,000,000,000 Rubles, Dec. 10, 1995, St. Petersburg.

85. Translated from a report written in 1996 by the attorney for CARP, GalinaKrilova (on file with author) [hereinafter CARP Report).

86. There have been visits of some major anticult figures from the United States and Europe to Russia, who have been involved in conferences on what to do about the problems of cults and sects. A future paper will describe some of this background activity relevant to how the idea of brainwashing has been imported into Russia by groups interested in exerting social control over the newer faiths.

87. For a detailed critique of brainwashing claims that explains the lack of scientific support for such claims, see Richardson, Recruitment to New Religions, supra note 1.

88. See CARP Report, supra note 85.