academic one and of very slight practical
importance. What is of importance is the recognition that malingering
and mental disease are here the expression of the same diseased soil,
and that the same source should perhaps be also attributed to this man's
criminalistic tendencies. Crime, mental disease, and malingering should
perhaps here be looked upon as different phases of a mode of reaction to
life's problems which belongs to a lower cultural level, which is
largely infantile in character.

That this infantile way of facing reality is dependent upon some
constitutional inherent anomaly is attested to by the circumstance that
these individuals practically always react in this manner when forced to
form new adjustments, new adaptations. This repeated recourse to mental
disease as a refuge from a stressful situation is amply illustrated in a
series of cases reported elsewhere.

The other form in which malingering may be so intertwined with actual
mental disease as to render accurate differentiation quite impossible is
where the individual may be suffering from a psychosis at one time, and
at some later period, finding himself in a stressful situation, malinger
a psychotic state. In these cases the danger of ever committing a
habitual criminal to a hospital for the insane is especially apparent.

Finding, as these individuals do, a successful and convenient refuge in
a psychosis, it is but natural for them to again seek this refuge when
they find themselves in conflict with the law. But that which was at one
time a spontaneous, unconsciously motivated mental reaction may later
become a conscious volitional act, an only available means of
escape--malingering of mental symptoms.

J. E. M., aged twenty-seven on admission, June 15, 1912. Family
history obtained from the patient four days after admission is quite
unreliable. He knew nothing of his grandparents, who died in Ireland.
Father was living when last heard from, four or five years ago. He is
moderately alcoholic; a stableman by occupation. Mother died at
fifty-five in Bellevue Hospital, New York City, from some unknown
cause. One brother was drowned. One sister died of tubercular
adenitis. No instance of epilepsy, insanity, or nervous disorder in
any form is known to have existed among his relatives.

Patient stated that he was born in Ireland on October 12, 1884. He
never attended school, but has learned to read and write a little.
Chil