In August 2001, the State of California Commission on Judicial Performance ordered the removal from office of Judge Patrick Couwenberg for making misrepresentations to become a judge, continuing to make misrepresentations while a judge, and deliberately providing false information to the Commission in the course of its investigation.¹ The judge had lied at various times to judges, attorneys, a newspaper reporter, and the Commission on Judicial Performance. He told the Commission, under oath, that he had participated in covert CIA operations in Southeast Asia and Africa and that he had a master's degree in psychology when, in reality, he had never been in the CIA nor did he have a degree in psychology. He had committed many other misrepresentations, including stating that he had received a Purple Heart for injuries sustained in Vietnam and dramatically reporting that shrapnel was still lodged in his groin. In reality, he was never in Vietnam during the war.¹

A psychiatrist expert witness testifying before a panel of three judges sitting as special masters investigating Judge Couwenberg concluded that the judge was suffering from pseudologia fantastica which he described as "story telling that often has sort of a matrix of fantasy interwoven with some facts" (Ref. 1, p 10). The expert further testified that pseudologia fantastica is treatable with therapy and did not render Judge Couwenberg unfit for judicial service. The basis for the conclusions regarding treatment and fitness for judicial service was not stated in the reference article and therefore is not available for review.

Cases like Judge Couwenberg's continue to emerge from time to time. Recent media articles chronicling the lying behavior of prominent men such as Joseph J. Ellis,² a Pulitzer Prize winning historian and professor of history at Mount Holyoke College; Jeffery Archer,³ member of the House of Lords of England; and Sir Laurens Van der Post,⁴ former spiritual adviser to Prince Charles and godfather to Prince William, have generated significant interest. A former student of Professor Ellis, upon learning of his mentor's lies was quoted as saying, "He seemed so genuine. Perhaps it was a fantasy he came to believe himself" (Ref. 5, p A12). This observation raised important questions: did the just-named individuals consciously and willfully engage in spewing their lies or were they unable to control their lying?

The concept of pathological lying, in which an individual repeatedly and apparently compulsively tells false stories, is not new to psychiatry. Numerous articles were written on it in the first half of the 20th century. However, interest in it waned drastically, to the extent that in recent years, it has received very little mention. Yet, the relatively modest light shed on pathological lying in recent psychiatric literature may not reflect its true prevalence in the pathology encountered routinely by clinical psychiatrists. Rather, it may be that psychiatrists simply know little about the subject and have difficulty recognizing the phenomenon.

Lies have been written about and classified for centuries. However, as noted by Healy and Healy,⁶ it was a German physician (Dr. Delbruck) who first clearly described the concept of pathological lying after an extensive examination of lies told by five of his patients. He concluded that these lies were so abnormal and out of proportion that they deserved a special category, which he described as pseudologia phantastica, terminology that is used interchangeably with pseudologia fantastica, which may be an Americanized spelling. Pathological lying, pseudologia fantastica, mythomania and morbid lying are generally used interchangeably, although it remains debatable whether they all describe the same phenomenon. Indeed, Bursten's⁷ description of Manipulative Personality shows characteristics similar to those of pathological lying. Nevertheless, for the purpose of this article, we make no distinction among the terms just described. In addition, we confine our discussion to the narrow phenomenon of pathological lying and do not consider the broader concept of lying. The latter subject has been the object of considerable discussion.

Many articles have variously defined pseudologia fantastica, but a commonly quoted definition is that put forth by Healy and Healy⁸ who described it as "falsification entirely disproportionate to any discernible end in view, may be extensive and very complicated, manifesting over a period of years or even a lifetime, in the absence of definite insanity, feeblemindedness or epilepsy" (Ref. 8, p 1). While this is a very comprehensive definition, it raises the question of whether definite insanity, feeblemindedness, or epilepsy must be absent for lying to be considered pathological.

Selling disagreed. He believed that "obvious mental disease, particularly a diagnosable psychopathic personality of some type" (Ref. 9, p 336) was responsible for pseudologia fantastica.

While no consensus definition for pathological lying currently exists in the literature, the identified functional elements of the phenomenon are: the repeated utterance of untruths; the lies are often repeated over a period of years, with the lies eventually becoming a lifestyle; material reward or social advantage does not appear to be the primary motivating force but the lying is an end in itself; an inner dynamic rather than an external reason drives the lies, but when an external reason is suspected, the lies are far in excess of the suspected external reason; the lies are often woven into complex narratives.

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Pseudologia fantastica was therefore described as a fantasy lie, a daydream communicated as reality, in which the lie can be a gratification in itself, for pleasure only and not for any other obvious gain.²⁰ It was described as an intermediary phase between psychic health and neurosis.²⁰ The notion of "double consciousness," in which two forms of life run side by side, the actual and the desired, and the desired becomes preponderant and decisive, has been proposed as the mechanism underlying pathological lying.²¹ It has also been suggested that the mental processes similar to those forming the basis of the impulse to literary creation in normal people is the foundation of the morbid romances and fantasies of those with pseudologia fantastica.²² The impulse that forces the fabrication of stories is supposedly bound up with the desire to play the role of the person depicted; fiction and real life are not separated. Further support for intact reality testing in pseudologia fantastica is the proposition that pseudologues usually have sound judgment in other matters, an observation that makes it difficult to prove that the pseudologue does not know that what he or she is doing is wrong.

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