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To cite this article: Stephen J. Lally (2001): Should Human Figure Drawings Be
Admitted Into Court?, Journal of Personality Assessment, 76:1, 135-149
To link to this article: http://dx.doi.org/10.1207/S15327752JPA7601_8
In recent years, there has been debate about the validity of figure drawings, although
surveys of clinicians in both general and forensic practice still find them to be one of
the most widely used tests of personality functioning. Using both Heilbruns (1992)
guidelines for the use of psychological tests in a forensic evaluation and the U.S. Supreme Courts Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993) criteria for the
admission of scientific evidence, I examine the admissibility of human figure drawings in court. The results suggest that the most commonly used methods for interpreting human figure drawings fall short of meeting the standards for admissibility. The
use of overall rating scales, although weak in validity, appear to minimally meet these
standards.
The formal use of human figure drawings to assess personality function dates back
more than 50 years (Machover, 1949). Although in recent years there has been debate about their validity (Dumont & Smith, 1996; Hammer, 1969, 1996; Joiner &
Schmidt, 1997; Joiner, Schmidt, & Barnett, 1996; Motta, Little, & Tobin, 1993b;
Riethmiller & Handler, 1997; Safran, 1996; Smith & Dumont, 1995; Waehler,
1997; Wanderer, 1969), surveys of clinicians in general practice (Lubin, Larsen, &
Matarazzo, 1984; Piotrowski, 1984; Watkins, Campbell, Nieberding, & Hallmark,
1995) have found human figure drawings to be one of the most widely used tests of
personality functioning. Similarly, surveys of tests used in forensic practice
(Ackerman & Ackerman, 1997; Borum & Grisso, 1995; Naar, 1961; Pinkerman,
Haynes, & Kaiser, 1993) also cite human figure drawings as one of the most frequently used tests. In fact, two of the most widely used child custody instruments,
the Bricklin Perceptual Scales (Bricklin, 1984) and the AckermanSchoendorf
Scales for Parent Evaluation of Custody (Ackerman & Schoendorf, 1992), incorporate human figure drawings in their assessment procedures. Within psychology,
there has recently been discussion (Heilbrun, 1992) about the minimum standards
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for selecting psychological tests in forensic assessments. Paralleling this move, the
courts have begun to articulate criteria for the admission of both scientific evidence
and evidence based on technical and other specialized knowledge (Daubert v.
Merrell Dow Pharmaceuticals, Inc., 1993; General Electric v. Joiner, 1997;
Kumho Tire v. Carmichael, 1999). With the use of Heilbruns guidelines and the
courts criteria, it is possible to address the question of whether human figure drawings should be admitted into court.
Heilbrun (1992), a clinical psychologist, published guidelines for determining
whether a given psychological test should be used in a forensic evaluation. These
seven guidelines cover both the characteristics of a given test and the particular legal context to which it is applied. The first guideline requires that the test is commercially available and adequately documented, both in its manual and in a
recognized publication that reviews psychological tests (e.g., Mental Measurements Yearbook). This requirement permits opposing counsel to examine and
evaluate the bases of the experts opinions. Next, the test is required to have adequate reliability. Heilbrun argued for a reliability coefficient of at least .80 because
a lower reliability would lead to unacceptably low validity. The third guideline requires that the test be relevant to the legal issue or to a psychological construct that
is relevant to the legal issue. It is further suggested that this relevance be supported
by validated research.
Heilbruns (1992) fourth guideline requires that the test have a standard method
of administration and that the examiner follow the instructions and conditions of
administration used when the norms were developed. The applicability of the test
to the population and the purpose for which it is used make up the fifth guideline.
In other words, an intelligence test would not be used to measure the presence of
psychopathology. There should ideally be a close fit between the validation research and the individual being evaluated. Heilbrun argued in his sixth guideline
that objective and actuarial tests are preferable. He based this argument on the general superiority in the research literature of objective methods of data collection
and actuarial methods of data combination over clinical methods for these tasks.
Finally, Heilbrun wrote that response style needs to be explicitly assessed by the
test; in other words, there must be a way to detect whether someone is malingering
pathology or feigning health. In short, the key points of Heilbruns argument are
that for a psychological test to be used for a forensic issue, it must have a solid scientific foundation, be commercially available, be able to detect malingering, and
be appropriate for answering the legally relevant question.
The courts have moved in a similar direction in terms of requiring expert testimony to be based on scientific method. Specifically, the U.S. Supreme Court, in its
triptych of rulingsDaubert (1993), General Electric (1997), and Kumho Tire
(1999)established a two-pronged test to determine whether an experts testimony can be admitted. Testimony must be both scientifically valid and relevant.
The court articulated criteria that the trial judge should use to decide whether testi-
137
mony is based on junk or genuine science; in other words, whether the reasoning
and methodology underlying the testimony are scientifically valid. The four criteria are that (a) the theory or technique can be and has been tested (falsifiability); (b)
the theory or technique has been subjected to peer review and published in professional journals; (c) there is general acceptance of the theory or technique in the scientific community; and (d), a fourth, two-part criterion, the theory or technique has
a known, error rate and there exist standards to control the operation of the technique. These four criteria were not meant to be exhaustive, and the court did not
state that testimony had to meet all four elements.
Although the standard for admission is relatively low, it is clear that the court
is trying to get trial judges to screen out testimony that is based on unreliable or
speculative sources. This conclusion was reaffirmed on February 22, 2000, in
Weisgram v. Marley Co. In this case, the court wrote since Daubert parties
relying on expert evidence have had notice of the exacting standards of reliability such evidence must meet (p. 1021). The justices went on to note that it is
implausible to suggest, post-Daubert, that parties will initially present less than
their best expert evidence in the expectation of a second chance should their first
try fail(p. 1021). Although this ruling is binding only in federal court, it is
likely that most state courts will follow this move to require that testimony be
based on scientifically valid evidence.
Before the application of these guidelines and criteria to human figure drawings, it is first necessary to define the test. Even limiting human figure drawings
to those techniques designed to assess personality functioning and ignoring
Goodenoughs (1926) and others work that have used drawings to estimate intellectual functioning, human figure drawings cover a wide universe. The most
widely known members are the Draw-A-Person, HouseTreePerson (HTP),
Draw-A-Family, and Kinetic Family Drawing. The slightly less popular members include Kinetic HouseTreePerson, Draw-A-Person in the Rain, and
Draw-A-School. Further complicating the matter is that the instructions and requirements for identically named tests can vary from researcher to researcher
and from examiner to examiner.
For this article, I have divided human figure drawings into three groups, largely
on the basis of the method used to interpret them. This division is not original, and
others have suggested similar variants (Groth-Marnat, 1997; Naglieri, McNeish, &
Bardos, 1991; Scribner & Handler, 1987; Shaffer, Duszynski, & Thomas, 1984).
The first method consists of clinicians and researchers using their global impressions to arrive at conclusions about the artists personality characteristics and level
of pathology. This is arguably the most widely used method and involves little or no
formal scoring. Instead, clinicians rely on their phenomenological experience of
the drawing, affective or visceral reactions to it, and relatively loosely reined impressions and associations (Scribner & Handler, 1987, p. 112) to arrive at their conclusions. The second method attempts to link single signs with specific aspects of
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Guideline
1. Commercially available, with manual and
independent review
2. Reliability of .80
3. Relevant to the legal issue or an
underlying psychological construct
relevant to the issue
4. Standard method of administration
5. Applicable to the population and purpose
used
6. Objective test and actuarial method
7. Measures response style
Global
Impressions
Specific
Signs
Overall
Ratings
+
+
+
+
Note. = method does not meet criterion; + = equivocal whether method does meet criterion; + =
method does meet criterion.
139
Although the manuals are flawed, this first guideline is, to a limited degree, met by
the first two interpretative methods. The overall rating method, as exemplified by
the DAP:SPED (Naglieri et al., 1991) and Van Huttons scoring system (Van
Hutton, 1994) do have commercially available manuals and have been independently reviewed (Cosden, 1995; Dowd, 1998; Knoff, 1998; Morrison, 1995). The
adequacy of the manuals and the tests themselves have also been criticized, but the
criticisms are less global and severe than they are for the other two methods.
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(1990) study, in which the raters appeared not to be given explicit criteria, resulted
in interrater correlations below Heilbruns level. These lower levels of reliability
are likely more representative of this approach in clinical practice. This conclusion
is supported by comments made by Hammer (1997), a major proponent of the impressionistic method:
Personality drawing interpretation is revealing itself to be more of an Art than a Science half of the psychologists are adept at this art, and about half are not . The research findings may be more dependent on the psychologists personality than on the
drawings, per se. (p. 377)
The data on the reliability of the specific-signs approach are not good (Groth-Marnat,
1997). Swensons (1968) review of the early literature found low interrater reliability (.23.52) and testretest reliability (.21.85). He concluded that structural and
content variables have reliabilities that are probably too low for making reasonably
reliable clinical judgments (p. 40). Adler (1970) also found low interrater reliability
for specific signs (.16.92), with only 12 of 32 specific signs reaching Heilbruns
(1992) suggested mark. A more recent review of the research (Kahill, 1984) found
interrater reliabilities for the most part over .80, and testretest reliability in one specific
signs study of .81. Kahill hypothesized that the improved reliability reflected researchers increased motivation to objectify their ratings and adequately train their raters.
The various overall ratings have generally been seen as having good interrater
and testretest reliability (Kahill, 1984; Swenson, 1968). The DAP:SPED, a specific overall rating scoring system, was reported (Naglieri et al., 1991) to have an
interrater reliability of .84 and a testretest reliability of .67 over a 1-week time period. These reliability scores partially meet Heilbruns (1992) standard, although it
is notable that some researchers (Bruening, Wagner, & Johnson, 1997) have suggested that because the majority of items on the DAP:SPED are scored infrequently, the method suggested by the test authors to calculate interrater reliability
might be somewhat inflated. Van Huttons (1994) scoring method is another specific overall rating. The manual (Van Huttton, 1994) reports that three of its four
scales have interrater reliability at or above .95, and the fourth has a reliability of
.70. The manual was criticized (Knoff, 1998) for not providing any information
about testretest or internal reliability and for relying on only two raters to provide
the estimate of interrater reliability.
3. The Test Should Be Relevant to the Legal Issue or to a
Psychological Construct Underlying the Legal Issue
None of the scoring methods purport to explicitly measure a legal construct; however, they all claim to measure psychological constructs (e.g., degree of pathology,
the presence of sexual abuse) that are potentially relevant to legal issues. The problem is that it is not clear if they actually measure these constructs.
141
To fully met Heilbruns (1992) standard, additional positive validation studies are
needed.
4. The Test Should Have a Standard Method of
Administration and Should Be Administered as
Close as Possible to This Standard
Manuals for both the global-impressionistic and specific-signs methods vary from
small (Burns, 1987) to considerable degrees (Buck, 1992) in the amount of information they provide about the standard method of administration. Both in clinical
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practice and in the research literature, there is considerable variability in how human figure drawing tests are administered and scored. Kahill (1984) noted that
some environmental factors (e.g., sex of the examiner, group vs. individual administration, specific instructions), which are often not controlled for in studies or clinical practice, can affect the results.
In developing overall rating systems, authors generally provide detailed information on the administration and scoring of the system. For example, the
DAP:SPED manual (Naglieri et al., 1991) describes in great detail administration guidelines and even provides plastic templates to aid in scoring. Van Hutton
(1994) was less detailed in her discussion of administration, and her scoring criteria for some items could be more detailed; however, the manual does appear to
meet Heilbruns (1992) minimal requirement.
143
processing of data. Although the overall rating system has a more objective scoring
method, the test is still projective in its data collection. The global-impressionistic
system exemplifies the clinical method of data combination as does, to a large extent, the specific-signs method. The overall rating method, with its cutoffs to determine the presence of pathology on the basis of normative samples, is akin to an
actuarial method. However, the overall ratings do not systematically measure outcomes, identify predictor variables, weigh the variables, and then cross-validate the
weighted variables.
Criteria
1.
2.
3.
4a.
4b.
Global
Impressions
Specific
Signs
Overall
Ratings
+
+
Note. = method does not meet criterion; + = equivocal whether method does meet criterion; + =
method does meet criterion.
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145
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specific-signs methods vary considerably to the degree that they have a standard
method of administration. This variability is reflected in both clinical practice and
the research literature. Generally, the overall rating systems provide detailed information on administration and scoring, and so these methods basically meet this
criterion.
CONCLUSIONS
It is clear that the two most commonly used methods for scoring human figure
drawings, global impressions and specific signs, do not meet most of Heilbruns
(1992) guidelines for use in forensic assessment and fall short of meeting the
Daubert (1993) criteria. These methods may arguably have a place in clinical practice, but they clearly do not belong in a courtroom. The conclusions with regard to
the overall rating scales, such as the DAP:SPED and Van Huttons (1994) scoring,
are less clear cut. They meet, or partially meet, a number of the guidelines and criteria, and they have the potential, with additional research, to meet more. Although
their validity is weak, their conclusions are limited in scope, and they appear to offer no additional information over other psychological tests, it can at least be argued
that they cross the relatively low hurdle of admissibility.
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Stephen J. Lally
American School of Professional Psychology
1550 Wilson Blvd, Suite 600
Arlington, VA 22209
Received March 30, 2000
Revised June 1, 2000