Vous êtes sur la page 1sur 19

Nora Gair Neuroscience and Criminal Justice Fall 2013

A Fair Trial: Exploring Juvenile Psychopathy from Legal and Medical Standpoints

In the early summer of 1968, eleven-year-old Mary Flora Bell (Fig. 1)was found guilty of strangling two toddler-age boys in Newcastle-upon-Tyne, England2. At her trial, she was deemed as demonstrating “classic symptoms of psychopathy” by court-appointed psychiatrists, as well as being externally described as “cunning” and “a show-off” by people who knew her. Dr. Samuel Orton, a psychiatrist who saw her soon after her incarceration, said “I've seen a lot of psychopathic children...But I've never met one like Mary: as intelligent, as manipulative, or as dangerous.” Though she was found guilty and sentenced to “Detention for Life,” she was released at age twenty-three and, with the daughter she had conceived during an escape years previously, she went on to lead a life under a new name, committing no acts of recidivism in any years since. Each of the three times she and her daughter‟s identities were found out, she fought hard to get new identities to keep them both safe, an act of caring that seemed beyond the realm of a “true” psychopath‟s caring. Too, in one of the books written with her about her childhood, she is quoted as saying, “...what I want most of all is a normal life” (Blanco, n.d.c) Whether or not these more “human” acts later in life are true remorse or from ulterior motives, and though testing for psychopathy has improved vastly in the past sixty years, there is enough doubt raised in this and several other accounts of juvenile psychopathy to beg deeper investigation into the validity of this diagnosis during adolescence from both legal and medical standpoints. This paper

Three of the most famous psychopathic murderers of all time--Edward Theodore Gein. execution. 2) of Wisconsin was found incompetent to stand trial by reason of insanity in 1957. . –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––– To begin to understand the nuances of the application of the diagnosis of juvenile psychopathy in the court system in regards to violent crime. He was sent to the Central State Hospital for the Criminally Insane for 1 This obsession with solely female body parts is attributed to his relationship with his mother. the year he was accused of having murdered two women and the year police had found numerous female1 human body parts fashioned into gruesome objects--a necklace of lips. Theodore Bundy. in line with other early suspicions about psychopathy resulting from purely environmental factors. and life in prison. though the diagnosis of schizophrenia was inconclusive to an extent. it was thought that her unstable home life with a prostitute for a mother and a professional thief for a father was the root of her psychopathy. In May Bell‟s case. He underwent a wealth of tests and was deemed a borderline schizophrenic and a sexual psychopath. and Jeffrey Dahmer--were all sentenced in different ways--confinement to hospital. Edward Theodore Gein (Fig. we must first look at the general treatment of adult psychopathic violent criminals by the court system. respectively. though many were found to have been from grave-tampering rather than murder. bowls made of skullcaps--all over his house.seeks to look at both sides of the trends in sentencing for adult psychopathic murderers and then look at evidence supporting and opposing the current norm for the sentencing of juvenile psychopathic murderers found guilty.

Bundy.” All of 2 Again. but was found guilty and sentenced to death. He was sent back to the Central State Hospital for the Criminally Insane for the remainder of his life. and told the court that Bundy had “sabotaged pretty consitently [sic] what the defense lawyers had worked out. however.ten years. Bundy would cooperate. Florida and beyond. especially of the violent type. psychopathy was a valid condition to rate insanity in the legal sense.that would terminate the show. Emanuel Tanay.. saying “I did not think that Mr.. Polly Nelson called to witness Dr. in this case attributed by Bundy‟s own testimony to early exposure to pornography. against the defense council‟s wishes. and it was outside his control. and there he was touted by his doctors as the model patient. Theodore Bundy (Fig. He was found guilty of first degree murder. with zero acts of recidivism until his death.” Tanay added that he had thought as much even before court proceedings went into effect. some argue. partly because. and the show would be over. managed to get his actual execution put off for many years for various reasons. His conduct was symptomatic of his illness. . He plead innocent. but mostly because the evidence against him was so incontrovertible.. but then found not guilty by reason of insanity due to his diagnosis as a psychopath. he would be just someone who was spared from the death sentence. (Blanco.with the advice of his lawyers …[and] take the guilty plea.d. during one of the appeals during which Bundy did not represent himself. because. 3)was found guilty on every count of murder he was accused of and tried for. a psychiatrist who had studied Bundy back in 1979 during the first trial. he served as his own lawyer and poorly so. his need was to have the proceedings go on and on in order to gratify his pathological needs. his ability to be the celebrity would come to an end. at which point his doctors deemed him sane enough for trial. Bundy only murdered women that we know of. In 1987. n. beginning in 1979 with the Chi Omega2 murders in Miami. Tanay defined him assuredly as a psychopath in his own expert opinion.d) Thus at least in the mid-twentieth-century. Whereas..

this interview was in an attempt to invalidate Ted Bundy‟s actions during his trials and render him insane at the time. had let Gein live out the rest of his days in hospital. It was an expression of his basic persoanlity [sic] structure”3 (Blanco. . though both opinions were held at the time and. 3 Here we see the evolution of the diagnosis of psychopathy to an integral part of one‟s nature. rather than solely an environmental issue. n.d. among other factors. This defense did not exonerate him in any way. although only twenty years earlier a diagnosis of psychopathy. It was not a temporary phenomena. corroborated by Tanay‟s statement that Bundy‟s behavior “was a lifelong pattern. indeed still are.a).

. totalling just a couple of years fewer than 1000 years in prison (though he was beaten to death in a prison bathroom by a schizophrenic fellow prisoner two years after his conviction. and then switched to not guilty by reason of insanity. murderous corporal crimes. your Honor.. in 1992. after again being a model prisoner á la Gein... this underlines the developing theory of psychopathy as an implicit facet of the nature of the psychopath. while the prosecution had the prove he did it but with intent. . he was the engineer!" 4 Again. The defense now had to prove that he did it and incredibly so.Jeffrey Dahmer (Fig. the longest sentence he uttered the entire time was “I understand. the defense eventually boiled down to something to this effect.This is Jeffrey Dahmer. As in the previous two cases. Dahmer was nearly silent. He pled completely innocent originally.” when asked if he comprehended the charges against him at the preliminary hearing. This changed the entire trial. and countless Polaroids Dahmer had taken himself showing other gruesome. was found guilty of fifteen murders and sentenced to fifteen consecutive life terms in jail. 4). a runaway train on a track of madness.) Pros to his final trial he had been accused of molestation and other crimes. a concise labelling of the debate over psychopathy as a defense of insanity: Defense: “."4 Prosecution: "He wasn't a runaway train. four heads in his refrigerator and freezer. in contrast to Bundy. At the trial for these murders. but when police investigated him for the final specific murders he was suspected in they found decomposing body parts in his cupboard.

insanity does not appear to be a viable plea. as well. Cima. even though both types of harms led to utilitarian gains.d. and non-psychopathic non-criminals.e. it appears that the law can affect the behavior of psychopaths” (n. They wrote that “subjects in each group judged cases of personal harms (i. non-psychopathic criminals.” These similarities can be seen in Fig.” This makes a clear distinction that the “emotional” part of morality.) One can glean from the above cases that insanity is one of the preferred defenses for those deemed as psychopathic murderers. however. 5 below.). As mentioned in passing in the footnotes. requiring physical contact) as less permissible than impersonal harms. though. need not apply to a criminal in order for him to understand what he has done wrong--again. does that plea match with the current expert definitions for psychopathic culpability in terms of the law? The Law Library of American Law and Legal Information asserts in its entry on psychopathy that “psychopaths are firmly in touch with reality. and Hauser presented their findings after delivering a version of the Moral Sense Test to psychopathic criminals. Many studies have been conducted on knowing objective “right” from “wrong” in psychopathic minds: In the journal Social cognitive and affective neuroscience. in this case when applied to law.From the three above cases. it is clear that over the twentieth century psychopathy has been viewed in several different ways resulting in several different outcomes in the legal court system. this in no uncertain negates insanity as a defense for psychopaths. How. “psychopaths‟ pattern of judgments on different dilemmas was the same as those of the other subjects. in what is self-described as “a general overview of psychopathy as it is currently treated in the law” about “how responsible is the . it is evident that the expert opinion on the causes of psychopathy as a mental disorder have begun to evolve (this will be spoken of more in depth in the next section of the paper. And yet.. Tonnaer.. They went on to add that.consequently.

the Law Library of American Law and Legal Information takes a very hard line on the subject: since they can understand in at least some form the law. One of the Texas decisions granted a writ of certiori by the Supreme Court was to require the jury to answer three specific questions about the defendant in order to sentence him to capital punishment. have these varying definitions of psychopathy affected sentencing? Surely these studies cannot attempt to exist in a vacuum outside of public use. How. Again. 2011). it is concluded by the authors after looking at numerous texts that “the nature of psychopathy appears to involve a sort of agency that bears a striking departure from that of a normally functioning adult” (Fox. which agains brings psychopathy into the realm of perhaps a too-altered a state of mind for full culpability for ones own criminal actions. and the rate of unsuccessful conditional release once retained of . including “(2) whether it is probable that the defendant would commit criminal acts of violence constituting a continuing threat to society. as well as the ease with which psychopaths attain conditional release relative to other inmates. though. Fontaine.psychopath for criminal wrongdoing.). Texas from 1976.d. which fits this question.” There is a high rate of recidivism of psychopaths. “psychopathy would then rationally be considered an aggravating factor that would warrant a harsher sentence and even death in jurisdictions that impose capital punishment” (n. Kvaran. This is in line with one of the points made in the Supreme Court Case Jurek v.

Hare. manslaughter) than the crime for which they had been prosecuted (e. And yet in the same study cited just above. but it measures psychopathy by ratings of 0-2 on various statements) were more likely to get a reduced sentence.g..psychopathic criminals (Häkkänen-nyholm. the variable that went along with the highest rate of reduced sentence--a rate of 4.3 times more likely to be given less time. 101 had been “convicted and sentenced for a criminal offense that was less serious (e. they found that those individuals who ranked higher an individual scored on the PCL:R test (which will be discussed later.” And that out of those 101. murder). 5 Too. Häkkänen-nyholm and Hare found that out of 546 psychopathic murderers. 2009).5 This again challenges the assertion of psychopathy as an “aggravating factor” warranting “harsher sentence (Law Library of American Law and Legal Information.). Interestingly.. Hare.d. 2009). non-psychopathic accused of the same crime. n. 42 had been convicted for only “involuntary manslaughter” (2009). to be exact--was pathological lying (Häkkänen-nyholm. .g. All of this would suggest that psychopaths are likely to receive harsher sentences than other.

prosecution/absent. the nature of the thought process on the roots of psychopathy has been evolving over time. 2012) (see Fig. from purely environmental to environmental. defense/present. but also neurological. In a study conducted on 181 state trial judges. yes. and defense/absent). Brown. the half that was shown evidence of psychopathy took into account more than half again as many percent mitigating factors as those who hadn‟t seen the biological evidence (Aspinwall. were given a psychopathic violent assault case to evaluate. This recent news on this second biological derivation of psychopathy is looking to further cause sentence lengths to drop. Tabery. all. 6 below).As stated above. in four groups (prosecution/(biological argument) present. Though they all listed aggravating factors more than mitigating factors in their judgment. .

Blair. Moffitt. 2005). In a twin-based study on genetics-based callous-unemotional (CU) traits6. were only similar to one another at a rate of 39%. for whom psychopathy would allegedly arise more from environment than genetic make up (though they are still siblings). The study further claimed that the environmental effect appeared to be only around 5% responsible for the similarities (Viding.or psychopathic behavior especially useful in the evaluation of juveniles for these mental disorders.(And the biological evidence for psychopathy is very much real. and too the lighter sentences many get in the first place. in truth. each possible outcome for a psychopath who ends up admitting to having committed the crimes. discussed later. the monozygotic twin were 73% similar to one another in terms of CU. with the rate that psychopaths recidivate and their ability to leave jail to do so through conditional release. perhaps the current view on psychopathy is 6 Again.) The past psychopathic murderer cases above have shown. whereas the dizygotic twins. but it’s a list of characteristics thought to be indicative of socio . However. . Plomin.

as this is the only real viable sentence these days for psychopaths who are not pleading innocence is a long jail time. He was deemed a psychopath by police psychologist Dr. execution of minors or juvenile offenders. –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––– With all the above information in mind. as it is assessed as a possible plea even less of the time for psychopathic juveniles (at 1.not serving justice and the courts well enough.‟” as well has Conley‟s “exhibition of boredom after the murder. even if being tried as adults as some juvenile psychopaths are (to be discussed below). Simmons (2004). and then weigh the evidence for and against the application of this diagnosis in the first place from both legal and medical standpoints. Young Andrew Conley (Fig. the juvenile psychopath. signifying his dissociation of emotional responses” and his self-admitted fascination with and desire to emulate the protagonist from the television show 7 Not guilty by reason of insanity is a negligible choice. 2010) .) is not the best nor most “rational” approach when dealing with this particular mental illness. perhaps the hard line suggested by the Law Library of American Law and Legal Information (n. setting them afire and making them drink bleach. rather than several. The general trend in sentencing for juvenile psychopathic murderers can be summed up in one modern case example. To be able to make judgements on this topic. 7) pled and was found guilty in an adult court in 2010 of the murder of his younger brother by strangulation.3% of the time) as compared to adult psychopaths (7. we must look at first the norms for the sentencing of this specific type of criminal. we can now turn to the questions of juvenile psychopathy as in play in the courtroom. Vincent. If so many found guilty are receiving lighter charges for the same crime as compared to other criminals. who cited characteristics such as his “fantasies about „skinning people alive. Because of the Supreme Court Case Roper v. James Daum. rather than execution 7. McLachlan.4% of the time) (Viljoen. is now considered a violation of the Eighth and Fourteenth Amendments.d.

n. to validate even considering trying them in adult courts and possibly giving these individuals the harshest sentence possible-life without the possibility of parole--we must look at both their potential for recidivism and the ameliorability of their condition.“Dexter.d. “judges typically consider the youth's potential for future violence and „amenability to treatment‟ in the juvenile system” (MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice. at least in the eyes of the justice system. –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––– . If this sentencing is so black-and-white from the get-go. In deciding which system to go with.b) Therefore. why delve deeper? Juvenile psychopaths can be tried in either an adult court or in the juvenile system. He was sentenced to life in jail without parole.” Conley pled guilty. and the speculation of a long prison sentence as his desserts was confirmed by the judges decision. This is the trend and the norm for any cases pertaining to psychopathic juvenile murderers of the modern era.

Robert Hare in the 1970s to be administered by clinicians. The PCL:YV is the 2004-revised version for juveniles aged 13-18 of the Psychopathy Checklist: Revised (PCL:R). The factors have to do with either antisocial behavior or affective personality functions.To understand these points at all. The PCL:R is a twenty-item list of factors that are rated at zero.d. The three main methods of diagnosing psychopathy in youths are the the Psychopathy Checklist: Youth Version (PCL:YV). Some . juvenile or not. the Youth Psychopathic Traits Inventory (YPI). the differences largely having to do with the availability for the subject involve himself in the behavior indicated (MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice. or two for manifestation in the subject of the test. one. No common cutoff currently exists for the PCL:YV. and the Inventory of Callous-Unemotional Traits (ICU). we must look at how one is diagnosed with psychopathy as a juvenile in the first place. 8 above). The PCL:YV and the PCL:R differ in very few ways. devised by Dr. is the most relied upon and common assessment of psychopathy. The PCL in any context.a) (see Fig. The typical cutoff score for psychopathy with the PCL-R (adult version) is 30. n.

g. they rate themselves again on a scale of zero to two on various psychopathic traits that are listed as positive attributes (e. Finally. I use my smile and my charm to use others.d.”).or psychopathy. Parent Report. there is the (least commonly used) ICU. With this scale.a). 2003) than behavior (MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice. others 30. (Dolan. officially diagnosing a juvenile with psychopathy by using any of these tests is still fraught with danger regarding the possibility of making an incorrect diagnosis of this 8 This would seem to indicate environmental factors are the major ones in the development of psychopathy. The YPI. 2010). Monahan. which unlike the previous two tests can be used separately or in conjunction with one another for a fuller picture of the subject‟s behavior and characteristics. Cauffman.suggest 25. created in 2002. n.d. though there is no yet data on whether this creates false positives of any type (MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice.). Teacher Report. In any case. [and] low behavioural inhibition. which [make] the child poorly responsive to socialisation”8 and at high risk for a later diagnosis of socio.a). is a fifty-item self-reporting test for individuals 12-18. 2004) 8 8 . but “subsequent studies in children with conduct disorder indicated that the style parents use to socialise their child has less impact on the development of conduct problems” than others had previously conjectured. but the research on these topics is so young there has been no consensus as of yet (Kimonis. Parent Report (Preschool Version).d. dishonest charm is listed as “When I need to. a 24-item test from 1998 that has five iterations: “Youth Self-Report. The major difference between PCL:YV and YPI is that the “YPI focus[es] more tightly on core interpersonal and affective features” (Skeem. n. Scoring high on the ICU is indicative “of a unique temperamental style. and Teacher Report (Preschool Version)” (Frick. n.

2009). also demonstrated in a separate study focusing on the difference between YPI and PCL:YV outcomes. irresponsible behavior. thrill-seeking. The other question is about the wisdom of diagnosing a person with such a serious disorder during the stage of life that is adolescence. these characteristics including “proneness to boredom. psychopathic traits as currently assessed in .raise serious questions about the use of such measures as the basis for legal or clinical treatment decisions” (2010). the bulk of research would suggest that youth do not exhibit these characteristics to [as] high [a] degree” as confirmed psychopaths do (Salekin. Kimonis and Monahan found that the subjects “were often identified as psychopathic by 1 measure but not by others.the inconsistent psychopathy designations. Too.a).. adolescents [sic] psychopathy scores are not as stable” (Cauffman. impulsivity. these claims or adolescent exceptionalism to the diagnosis are refuted with a similar vehemence elsewhere.). the nature of adolescence. Lee. n. Rosenbaum. and egocentricity. and Many sources point out various inconsistencies between the results of the different methods for testing for psychopathy in adolescents. When testing a group of youths with three different methods. “Relative to adults. with sources saying that although “adolescents exhibit impulsivity. Skeem.. Lester.d. and poor behavioral control. Lester.d. Lee. “seems inconsistent with the notion that adult models of psychopathy can simply be extended downward to youth” (Cauffman. 2009). n..” not just “markers of an irredeemable character” as they are seen in adults (MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice. with “a good portion of youth deescalat[ing] in psychopathic characteristics over time” (Salekin.. ” which are also “normal and often transient developmental characteristics of adolescence. However. 2003).disorder particularly tricky to identify correctly in adolescents. Skeem. Rosenbaum. These caveats largely sort into two categories: problems with testing. This serious disparity.

and this is one of the factors a judge considers when sending a young psychopath on his way to the adult justice system. However. at least insofar as it matches the predicted dangerousness of the subject. –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––– The above information discusses the medical aspects of juvenile psychopathy.than non-psychopathic criminal youth” (Dolan... we may not know the direct ins and outs of juvenile psychopathy from a medical or neurological standpoint. and so we must proceed as such until any doubt is ultimately erased or confirmed. this is simply the best way to deal with whether or not a juvenile deserves chance of early/conditional release or not. McLachlan. and the possibility of treatment. no matter any doubt. and Lester. “findings on child psychopathy raise many more questions than they answer” (2009). In the eyes of the court... determining future delinquency is only a question necessary to answer if considering the death penalty. Texas. is a “robust predictor of violence and reoffending” (Viljoen. For a while yet. but it is accepted as a diagnosis legally as yet. however. 2001) because the non-antisocial variables... 2010). having psychopathic tendencies. especially on . As concisely summed up by Salekin. and more violently.youths puts a juvenile on a path that sets him up to “have an earlier onset of offending. Lee. however.commit more crimes. and reoffend more often. juvenile psychopathy is another beast entirely. there needs to be conducted “more research that looks specifically within the adolescent population at the predictive utility of those elements of psychopathy that are not themselves indicators of current antisocial behavior” (Steinberg. Rosenbaum. This side of the debate deals almost exclusively with the possibility of recidivism. 2004). In Jurek v. however tested. These data underscore the validity of the diagnosis of psychopathy. since capital punishment is off the table. According to many studies. Vincent.

especially with some doubt already cast onto the validity of the diagnosis in the first place. Fernandez. Guy. and as they are evaluating juveniles. are more correlated with recidivism in adults and there is a gap in the knowledge with this in regards to adolescents. 2003).the PCL tests.) This casts doubt onto the true predictability of exact replicas of crimes committed if allowed back into the general society. especially in regard to adolescents. as it is a mental disorder. so the statement stands. for example. there is doubt if these predictions of recidivism in psychopaths are enough to form firm opinions on the matter. As such. and Fernandez argue that despite the connection established between psychopathic tendencies and future run-ins with the law. Guy. it bears some amount of right thinking that each and every danger of prejudice or incorrectness be looked at twice for these individuals. of the studies done on inmate violence perpetrators in US prisons. it would seem that life without parole being applied to an adolescent who has been diagnosed with psychopathy is a choice fraught with risk of incorrectness and injustice. But. No one is arguing that individuals admittedly having committed these crimes are not dangerous or are entirely blameless in their guilt. As Cunningham and Reidy state in conclusion of their study. “in common usage the terms used to describe [psychopathy] have a connotation of dangerousness and arguably an emotional flavour that strongly militates against rational evaluation of their objective value in predicting assaultive conduct” (1998). This unfair leaning should be prevented at all costs. “none has obtained a significant correlation between psychopathy (as operationalized by the Hare PCL measures) and physically violent behavior” (Edens. Too. Edens. . “research fails to support the claim that psychopathy predicts the types of violence that are at issue in capital cases” (2003) (which the majority of these cases would be were the defendants older. Too.

In fact. Worley. even if not fully erased10. previously thought to be incurable. However. as noted by Reidy. Worley. But if not harsh jail time. and more explicitly. Similarly. Kearns. despite” the past associations made 9 There are many strategies currently being used and improved upon for the rehabilitative therapy of psychopaths. „„few clinicians who work with psychopathic [prisoners]. but impressive nevertheless (Salekin. 2003). Grimes. Grimes. after reviewing certain juvenile psychopaths rehabilitated at one center. 2010). 10 Three out of the eight studies also showed improvement in the adult psychopathic group--a less promising estimate. can be mitigated somewhat over time. Skeem. some are now coming to think that “assumptions of untreatability are just that:” assumptions. . then what? –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––– Rehabilitation9 is an angle rarely thought of for psychopathic individuals. “no relation between psychopathy scores and violent or general recidivism existed at 4 year follow-up. it would follow that treatment be rarely applied to them.There is so very much room for doubt among all the legal and medical cautions dealing with this diagnosis that it seems foolhardy to apply the harshest sentence possible--life without parole--to the individuals. This is promising because it shows that the effects of this disease.. Steinberg adds that “juveniles who are branded as psychopaths are more likely to be viewed as incorrigible. with “recent evidence [suggesting] that psychopathic youth could develop into nonpsychopathic [sic] adults” as a result of various therapies (Petrila. Because the definition of psychopathy largely includes the descriptor untreatable. 2003). As stated in one study. and DeGue.. but the pros and cons and type of those are another paper entirely. less likely to receive rehabilitative dispositions” (2001). 2010).offer much optimism for rehabilitating a truly psychopathic youth in that period of time” (Petrila. Skeem. six of eight studies on psychopathic youth under treatment show them to be “improving” or becoming less psychopathic as a result (Salekin.

who is anyone to deny a youth at least a gleam of a chance for a future not defined by their condition? The real concern is.about this correlation(2013). like the two out of eight not showing improvement to Salekin. now and in the future. with the possibility of real treatment just over the horizon--how can we condemn these adolescents in this so bleak and defined way? It looks as if we shouldn‟t. or several others noted by Reidy. However. 2013). with the past view of the disease being so negative any hope now for these individuals is squashed out. With the possibility that the disease is nigh undiagnosable in juveniles. . This research is in its infancy. Also. and there are of course some studies where rehabilitation or treatment have been shown not to have helped the mental condition of these juvenile psychopaths. And with more research conducted. they noted that the “high ps ychopathy youths incarcerated and treated [there] were significantly less likely to violently recidivate at two year follow-up” (Reidy. with the glimmers of hope for treatment and rehabilitation in the very near future as the burgeoning area of research is furthered in every direction. yes. and Grimes (2010). DeGue. as Steinberg puts it. but to keep our country fair and just. “that assessments of juvenile psychopathy are not being used to recommend further evaluation but are instead forming the basis for definitive dispositional decisionmaking [sic]” (2001). Kearns. Worley. we can keep improving our picture of juvenile psychopathy to keep us all safe. Kearns and DeGue (2013). or at least not as a stable condition.