Another case of this kind was reported in 1890: a well-known English author was said to have filched a work from a brother literary man whom he had hypnotized, and then published it as his own.

There are important differences of opinion about the offences which hypnotic subjects may be caused to commit. Liegeois thinks this danger very great, while Delbceuf, Gilles de la Tourette, Pierre Janet, Benedikt, Ballet, Foveau de Courmelles, and Kotscher deny it altogether, and others, Joire, Forel, Eulenburg and Dalley take an intermediate position. Liegeois thinks that about 4 per cent. can be influenced by criminal suggestion; this would give about 80,000 people in Berlin. Others, as already observed, deny the danger entirely. In any case we must not be too ready to believe the stories of robbery we find in the newspapers; they are written rather to "make people's flesh creep" or create a sensation than to advance science.

There is no doubt that subjects may be induced to commit all sorts of imaginary crimes in one's study. I have hardly made any such suggestions, and have small experience on the point. In the first place, the continuous repetition of the same experiment is superfluous. If the conditions of the experiment are not changed, it is useless to repeat it merely to confirm what we already know. In the second place, these criminal suggestions are repugnant to me, although I do not believe they injure the moral sense of the subject, for the suggestion may be negatived and forgotten. Thirdly, experiments carried out in the study prove nothing, because some trace of consciousness always remains to tell the subject he is playing a comedy (Franck, Delbceuf), consequently he will offer no resistance. He will more readily try to commit a murder with a piece of paper than with a real dagger. These experiments carried out by Liegeois, Liebeault, Foureaux and others in their studies do not, therefore, prove the danger.

Certainly Liegeois has made some such experiments in all apparent earnestness, and in the presence of officers of the law, by hypnotic and post-hypnotic suggestion, and even by suggestion in the waking state. He made a girl fire a revolver, which she thought was loaded, at her mother; and another put arsenic in the drink of a relation. Delbceuf shows good reason for not considering these experiments convincing. Yet we must admit the possibility that a crime may be committed in this way, though we must be on our guard against any exag-geration in this respect. Few people are so suggestible as to accept the suggestion of a criminal act without repeated hypnotization. It is also true that many would refuse to commit a crime even after a long hypnotic training (Delbceuf). If Kahler really thought that imperative ideas produced by hypnotic suggestion resemble impulsive ideas of pathological origin, particularly on account of their violence, we cannot agree with his conclusion that post-hypnotic imperative ideas never lead to acts of violence, since pathological impulsive ideas do sometimes lead to such acts.

According to Gilles de la Tourette we are specially protected from such crimes being committed by the fact that a criminal who suggested any such offence would be no more protected from discovery than if he committed the crime himself. On the other hand, Forel insists that the greatest danger is that at the time the criminal suggestion is made the subject may be induced to believe that he is acting on his own initiative, and is unaware of any constraint. Still, as most investigators assume, only people whose general moral character renders them capable of committing criminal acts could be influenced in this way. Forel, however, does not admit this unconditionally* He made various experiments, for the purpose of enlightening a lawyer named Hofelt, who was writing a dissertation on the connection between hypnotism and criminal law. In one case, for instance, he induced 9. hypnotic subject to fire several shots at Hofelt with a revolver that was capped but not loaded. According to Forel, the experiment was so arranged that the hypnotic could not have been conscious that he was only playing at shooting, though I think we cannot straightway accept this explanation.

It was different, however, in the case of an otherwise modest girl, who was yet induced by Forel to strip to the waist in the presence of a strange man. Forel thinks that this experiment disposes of the objection that only such acts can be successfully suggested in hypnosis as are agreeable to the subject's moral disposition. I myself think that we must admit that in exceptional cases it is possible for a person to be induced to commit acts that are contrary to his disposition, but that there is not any great general danger from criminal suggestion. In any case the sphere within which such suggestion would work must necessarily be a very limited one. "We may take it as a general rule, that the criminal acts we should have to deal with here are those which demand no special aptitude on the part of the agent - no particular qualification, that is to say - nor any special preparation, nor such complicated manipulations as would involve deliberation and perspicacity, nor yet the cooperation of others" (M. Weiss).

In remarking just now that the general importance of suggestion in criminal cases did not appear to me very great, I would yet make it clear that we must carefully distinguish between its general practical importance and its significance in any special case. For the above-named reasons the general importance is slight. But it is quite another question whether hypnotic suggestion must not be taken into serious consideration in a concrete case in which, for instance, the accused person has not only been constantly hypnotized, but the hypnotizer is also known to derive considerable advantages from the crime, whilst other circumstances point to his participation. And this question we must certainly answer in the affirmative.