E-FILED

6/15/2020 12:00 AM
Clerk of Court
Erik Estavillo
Superior Court of CA,
3284 Cortese Circle
County of Santa Clara
San Jose, CA. 95127
ZOCV367206
(408) 593-1226
Reviewed By: P. Lai
webbbnet@a01.com

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA

Erik Estavillo, CASE NO 20CV367206

Plaintiff,

COMPLAINT
VS.

JURY TRIAL DEMANDED

Twitch (0f Amazon Inc),

Defendant.

1. Jurisdiction

This court has jurisdiction over this lawsuit because it arises under the laws 0f California

and the defendant is located in San Francisco, California 0f which all 0f the acts and
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grievances against the plaintiff have also occurred in the Bay Area, more specifically here in

San Jose, California, within the County 0f Santa Clara.

2 Venue

Venue is appropriate in this Court because both the plaintiff and the defendant are in the

Bay Area of California and all 0f the acts and omissions giving rise t0 this lawsuit occurred

here. Furthermore, it is under California State Law that one 0r more 0f the claims against the

defendant are based.

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 3. Intradistrict Assignment

This lawsuit should be assigned t0 the San Jose Division 0f this Court because all events

0r omissions occurred t0 the defendant here in San Jose.

Introduction/Statement 0f Facts
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4.

The plaintiff has been a Twitch Prime and Turbo subscriber for years now, whom also

suffers from Depression, OCD, Panic Disorder, Agoraphobia and Crohn's Disease.

And because 0f these maladies, he heavily relies 0n the internet for all his entertainment

purposes as many others d0 during this difficult time. And due t0 the COVID-19 pandemic,

many people HAVE TO STAY HOME FOR ENTERTAINMENT and are quarantining

themselves, including the particularly vulnerable - children. As for the plaintiff, he only

leaves his house for Inflectra infusions having t0 deal with his Crohn’s disease;

otherwise, he’s always 0n the computer constantly using and watching Twitch. Mr. Estavillo

suffers from Sex Addiction due t0 his Obsessive-Compulsive Disorder that makes him

obsessed with sex and compulsions. Twitch has extremely exacerbated his condition by

displaying many sexually suggestive women streamers through Twitch’s twisted

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programming and net code making it nearly impossible for the plaintiff t0 use Twitch without

being exposed t0 such sexual suggestive content. There is n0 way for the plaintiff to filter

streams he’d like t0 watch based 0n gender, male 0r female, therefore the plaintiff has to

choose a game and/or category t0 watch, with thumbnails showing these scantily clad

women, alongside men, 0f being the only streaming channels available t0 him. He cannot

filter out the women 0n the site, n0 Viewer can. Twitch doesn’t have a gender filter 0r

preference for a Viewer t0 choose t0 only watch men 0r women. Therefore, Mr. Estavillo is

exposed t0 all genders while searching for any type 0f stream. In addition, Twitch also takes

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 advantage 0f the plaintiff and many other sexually addicted Viewers by allowing them t0

“Subscribe, Donate, 0r Pay Bits” t0 these women streamers who are only streaming with the

sole purpose 0f taking advantage 0f such disadvantaged individuals who just want t0 watch a

Video game stream through Twitch, but then are enticed t0 spend money 0n these women for
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attention and sexual innuendo the streamer may d0 when donated t0, i.e. blow a kiss into the

camera and make sexual ASMR noises t0 entice the sexually addicted Viewer t0 donate more.
Twitch uses this immediate gratification reward system against their sexually addicted

Viewers n0 different than how a Casino would 0r how the website Chaturbate.com operates.

Twitch just doesn’t care as they should and AS IS EXPLICITLY WRITTEN BY THEIR

OWN LAWYERS IN THEIR OWN TOS SHOWN BELOW.

“2. Use 0f Twitch by Minors and Blocked Persons”

“The Twitch Services are not available t0 persons under the age 0f13. Ifyou are
between the ages 0f13 and I8 (0r between I3 and the age oflegal majority in yourjurisdiction
ofreSidence), you may only use the Twitch Services under the supervision ofa parent 0r legal
guardian who agrees t0 be bound by these Terms OfService.

...Nudily and Sexual Content in Embedded Media and Games

Embedded Media

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Situations, we may make exceptions 0n Twitch-owned and operated channelsfor content that is
rated by a ratings body 0r otherwise pre-screened by Twitch.

User-Generated Sexual In-Game Content

Focusing your broadcast around sexual content 0r in-game nudity in an otherwise allowed game
will result in enforcement action against your Twitch account. When interacting with in-game
nudity 0r sexual content in a permitted game, users may only Spend as much time as is required
t0 progress. In addition, users may not engage in Simulated sexual activity 0r erotic roleplay—
which includes the Specific behaviors listed under Sexually Suggestive Content above—with
otherplayers in online games.

Games thatprimarily consist ofuser-generated content, in-game roleplay, 0r interactions in

virtual reality are not exemptfrom this policy.

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 T0 maintain the health Ofour community andpromote content that is appropriatefor a diverse
audience, sexually suggestive content is prohibited 0n Twitch. Evaluations 0n the sexual
suggestiveness ofa behavior 0r activity are independent Ofuser attire and are instead based 0n
the overall surroundingframing and context. This policy also applies t0 embedded media,
augmented reality, creative broadcasts, and channel content—such as banners, profile images,
emotes, andpanelS—that arefocused 0n provocative images 0r video.

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Content that is considered t0 be sexually suggestive includes, but is not limited t0:

o Content 0r camerafocus 0n breasts, buttocks, orpelvic region, includingposes that

deliberately highlight these elements

o Groping 0r explicit gestures directed towards breasts, buttocks, 0r genitals

o Fetishizing behavior 0r activity, such asfocusing 0n body partsfor sexual gratification

0r erotic role play...

Additional Restrictions

Conversations about sex, nudity, and other mature topics that are intended t0 be educational and
otherwise comply with our policies Should be marked as Mature Content via the respective
”
channel ’S settings.

However, as you can see from the screenshots below, twitch did not permanently ban

these Violators 0f their own TOS; as all 0f these female streamers continue t0 operate and

influence kids under the tender age 0f 13 and all because these female streamers continue

t0 generate Twitch a lot 0f revenue, Via subscriptions, donations, and bits — 0f which

Twitch takes more than half. As you can see, these women continue t0 expose Viewers who just

want t0 see people playing Video games 0n Twitch, but instead get exposed t0 sexually addictive
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material and content 0n a consistent and regular basis, daily:

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 Twitch Streamer - Amouranth

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 Twitch Streamer — ST Peach

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 Twitch Streamer — DanielaAzuage_

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 Twitch Streamer — iaaraSZ

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Twitch Streamer - theRavchul

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...And in many Twitch page links t0 their “! Socials” which include all 0f
cases, their official
Twitter, Instagram, and Patreon — where children can easily access more illicit photos as you can
see below.

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 Twitch Streamer — KrystiPrvde

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 Twitch Streamer — SoniaShio

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 Twitch Streamer — Gavrilka

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 Twitch Streamer — Pokimane

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 KOOONOUI-PUJNt—t

A11 0f these streamers still operate today as the most popular streams 0n the channel and

provide Twitch with the most income generated — as well as providing links t0 their

instagrams 0n their Twitch Home Pages for easy access t0 more lewd photos. These

instagrams are linked 0n their Twitch page in the info section below for the sexually—addicted

and for underage kids t0 click on in order t0 easily access more sexually—explicit material.

However, the cream 0f the crop. .Twitch’s most egregious

. act yet. . .is OFFICIALLY
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PARTNERING WITH A PORN STAR KNOWN AS SASHA GREY, who attracts anywhere

from 2,000 — 7,000 Viewers 0n a daily basis, some 0f which undoubtedly are 13 years 0f age

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0r younger.

Twitch Streamer — SashaGrey

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 6. Claims and Harm

The plaintiff who suffers from Sexual Addiction has suffered much worse given that Twitch

has exacerbated his condition. The plaintiffs username 0n Twitch is ‘therealerikestavillo’ and he

is following exactly 786 female streamers while following zero male streamers with that number
KOOONONUILUJNu—A

continuing t0 grow as the plaintiff has little control over his addiction. Twitch does not limit how

many female Viewers a customer can follow Via their website. Attached t0 this lawsuit is the

“Ley-Forensic Applications 0f Sex Addiction” which depicts many examples 0f previous

lawsuits in which case-law is well established depicting those companies such as Twitch can be

held liable for their misconstrued and devious actions if done with extreme disregard for the

consumer’s well-being through negligence 0r fallible company policies. Listed below are

examples, although a bit graphic, are 0f the utmost importance t0 display how Twitch’s

laxed policy-enforcing has harmed the plaintiff by not filtering out these sexually suggestive

women and their content:

a) The Plaintiff had purchased a flashlight previously which went largely unused, until
Twitch. Mr. Estavillo began using this device while he watches female twitch
streamers and often ends up chaffing his penis everyday with the device - making it

extremely painful and constant which ends up causing redness and mild infections at

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the tip, (since the flashlight is electrical and also vibrates). The plaintiff therefore
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b) The Plaintiff often stays up for hours staring at the breasts 0f girl streamers, which
ends up damaging his retina and making his eyes blood shot for days; eye drops d0
nothing to hide his shame from his parents and he is often questioned by people he
comes into contact with as t0 why his eyes are so bloodshot and red - which leads t0
furtherembarrassment and isolation.
c) The Plaintiff once ej aculated 0n his PC monitor, causing a short circuit and small fire
within the electrical system 0f his gaming rig and causing his apartment t0 black out
temporarily.

In conclusion, please read the attached Ley-Forensic Applications 0f Sex Addiction pdf

for more information on sex addiction, the harms, and how previous case-law can and

should be applied t0 this case as well.

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PLAINTIFF’S
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 7. Twitch’s Policv/Service Reputation

Twitch already has a shoddy reputation as can be gleaned from each 0f their

current Prime services below 0f which ALL under-deliver and some outright defraud the

consumer through nefarious measures, practices, and policies.

KOOONONUILUJNu—A

- Twitch Turbo - Ad—Free Experience across Twitch

“With Twitch Turbo you’ll never see ads, with the exception affrontpage takeovers. Twitch
Partners and Affiliates still get creditfor ad impressions when a Twitch Turbo subscriber
”
watches their channel.

However, twitch violated plaintiffs rights t0 avoid seeing ads because when he was

erroneously banned from certain streamers’ channels, he had t0 create another account in

order t0 see what was being said in these streamers’ chat rooms (as Twitch has recently

begun denying turbo subscribers the right t0 even SEE chat rooms when banned for any

reason whatsoever). Twitch has essentially taken away the whole chat feature system already

in place from any banned turbo subscribers that are still paying for their “ad-free” turbo

service. And now, in order t0 engage in these chat rooms 0r t0 even at the very least SEE the

chat, twitch turbo subscribers must now create a non-turbo account t0 see the chat rooms —

which now all include ads.

- Twitch Prime - Free Games with Prime

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Twitch announced Free Games With Prime in March 0f 2018 t0 be 0f the same value

and in the similar vein 0f Microsoft’s Games with Gold 0n Xbox Live, Game Pass, 0r Sony’s

offerings alongside the PlayStation Plus service. However, Twitch Prime continues t0 under-

deliver as you can see in their most recent listings 0f free games in the screenshot below,

despite Prime costing well over $100 VS. Xbox’ Game Pass which is just $9.99 a month. This

alludes t0 false advertising as Amazon deceitfully oversold their Twitch Prime Gaming

service.

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 Games with Prime

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These games are hardly up-to-par compared t0 what other gaming services are offering at the

moment and at an even more reduced price; meaning Twitch is over selling their Prime

service and have committed false advertising.

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Twitch also allows “hosted raids” by these female streamers t0 promote other sexually

suggestive streamers in an endless cycle. These “legal” hosted raids essentially act like

Viewbots t0 artificially inflate any one particular streamer’s View count — as some streamers
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either pay for a host 0r are friends with these people who ‘host’ 0r ‘raid’ them. Not t0

mention, Twitch has a bad reputation by still artificially inflating their overall site numbers

and is guilty 0f other dubious “legal” methods 0f inflating View counts so that they

can promote certain streamers 0r games for profit as can be gleaned from these articles and

its investigations so—there within - https://k0taku.com/th'tch-loophole-z's-stz'll—

infla ting—views- I 84 005 6650 and httpS://k0taku. com/as-esportS-grows-expertsfear-its-a-

bubble-readV-to-po-1834982843

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 7. Request for Relief

Plaintiff respectfully prays for a judgment against Defendant for:

i. Injunctive and immediate cancellation and PERMANENT BAN of the female

streamers listed above, along with any other female (0r male) streamers that
KOOONONUILUJNu—A

Violate Twitch’s own TOS in a similar way. Also for the permanent ban 0f any

and all female (0r male) streamers that have not yet been PERMANENTLY

banned for such sexually suggestive content as has been displayed in this lawsuit.

ii. $25 Million in punitive damages t0 be split between the plaintiff and other

Twitch Prime Turbo Subscribers, with any monies left over t0 be donated t0 both

COVID-19 and Black Lives Matters charities and funds 0f the Court’s choosing.

By:/s/ Erik Estavillo ,

Erik Estavillo
Pro-se, Pro-per

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 Current Sexual Health Reports
Forensic Applications of "sex addiction" in U.S. Legal Proceedings
--Manuscript Draft--

Manuscript Number. CSHR-D-1 5-0001 O

Full Title: Forensic Applications of "sex addiction" in U.S. Legal Proceedings

Article Type: Review Article

Corresponding Author: David Ley, PhD

New Mexico Solutions
Albuquerque, NM UNITED STATES
Corresponding Author Secondary
Information:

Corresponding Author's Institution: New Mexico Solutions

Corresponding Author's Secondary

Institution:

First Author: David Ley, PhD

First Author Secondary Information:

Order of Authors: David Ley, PhD

Julie M. Brovko, MS
Rory C. Reid, PhD
Order of Authors Secondary Information:

Powered by Editorial Manager® and ProduXion Manager® from Aries Systems Corporation
Manuscript
Click here to download Manuscript: Ley-FINAL MS for upload.docx
Click here to view linked References

SpringerLink Header: Variations in Orientation, Identity, Addiction, and

mdofitfiwaH

Compulsion (E. Coleman, Section Editor)

Forensic Applications of “sex addiction” in U.S. Legal Proceedings

Corresponding Author:

David Ley, Ph.D.

707 Broadway NE # 500, Albuquerque, NM 87102

p. 505-248—2724 email: davidleyphd@gmail.com

Julie M. Brovko, M.S.

Department of Psychology, 1 University ofNeW Mexico, MSCO3 2220, Albuquerque, NM
87 106.

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p. 505-925-2329 E-mail: jbrovko@unm.edu.

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Rory C. Reid, Ph.D.

UCLA Department of Psychiatry and Harvard Medical School, Harvard University
760 Westwood Plaza, Suite 38-153, Los Angeles, CA. 90024 e-mail: rreid@mednet.ucla.edu

Keywords: “Sex addiction;” Sexual compulsivity; Sexual impulsivity; Erotomania; Hyperphilia

and hypersexuality; Forensic testimony; Civil law; Family law; Criminal law
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4 Abstract
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8 The term “sex addiction” has been popularized in recent years to describe a range of different
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problematic sexual behaviors which are assumed to be similar to being addicted to substances
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13 and lend themselves to similar treatment approaches. Other terms such as sexual compulsivity,
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15 sexual impulsivity, erotomania, hyperphilia and hypersexuality have been proposed in the
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18 literature which assumes different mechanisms and treatment approaches. However, the term
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20 “sex addiction” remains the most widely used and recognized label, particularly in public
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23 parlance. The current paper presents several case examples to illustrate how the concept of “sex
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25 addiction” is having a significant impact in United States’ legal proceedings. The authors offer
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some commentary about the relevance of these cases as they pertain to matters of criminal, civil
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30 and administrative law.
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37 Introduction
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41 While “sex addiction” is a popular concept or label for out of control and problematic
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43 sexual behavior, it is not a recognized or accepted mental health diagnosis [1]. As there has been
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46 a growing recognition of some kind of clinical syndrome regarding this non-paraphilic but
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48 problematic types of behaviors, there was a recent proposal to include “hypersexual disorder” in
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51 the recently published DSM-5. However, this diagnosis was not included due to controversy and
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53 a need for more research [2-4].
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4 In the development of DSM-5, “sex addiction” was challenged as a construct meeting the
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7 strict criteria for a pathological condition [3]. A proposal for “sex addiction” was considered, but
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9 rejected, by the DSM-5 Addictive Disorders Workgroup [2]. A proposal for “hypersexual
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12 disorder” presented sexual behaviors and problems in a manner intended to present a clinical
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14 syndrome without relying solely on one model, including addiction. Hypersexual disorder was
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17 proposed by the DSM-5 Committee on Sexual and Gender Identity Disorders for DSM-5.
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19 However, hypersexual disorder was excluded by the Board of Trustees of the American
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21 Psychiatric Association for an array of reasons [4]. Moreover, the DSM-5 contains the explicit
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24 statement: “groups of repetitive behaviors, which some term behavioral addictions, with such
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26 subcategories as “sex addiction”, “exercise addiction,” or “shopping addiction,” are not included
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29 because at this time there is insufficient peer-reviewed evidence to establish the diagnostic
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31 criteria and course descriptions needed to identify these behaviors as mental disorders” [5].
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35 Despite mental health clinicians being unable to render a formal diagnosis of “sex
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37 addiction”, testimony and evidence related to the concept, diagnosis or treatment of “sex
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40 addiction” is receiving increased attention in American courts, “where litigants are putting them
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42 to use in forming novel claims and defenses” [6]. The potential for forensic misapplication of
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45 “sex addiction” (or the related concept of hypersexual disorder) was raised during DSM-5
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47 discourse related to sexual disorders [3]. Despite the need for such a discourse, this article to our
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knowledge represents the first published work in the social science literature describing how this
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52 concept is being utilized in forensic proceedings.
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56 Case examples depicting the applications of the “sex addiction” construct in legal matters
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58 are presented below. These cases were identified through Google Scholar, Lexis-Nexis, and
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4 media sources and should not be considered exhaustive, but rather, a sample of current uses “sex
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7 addiction” that might be establishing some legal precedence. All case examples are drawn from
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9 legal documents and summaries in the public record. Although these records include the names
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12 of individuals and professionals involved, the descriptions herein use initials to preserve some
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14 anonymity for these individuals. All such cases are complex, and presentations herein are
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17 abbreviated to relevant details. Cases presented were chosen as reflecting key aspects of the role
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19 of “sex addiction” in these types of law. However, other cases may exist which reflect other,
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21 unaddressed aspects.
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25 While there are similar cases of “sex addiction” claims in judicial proceedings in other
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countries, the current paper is focused on United States’ law. This reflects the degree to which
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30 the concept of “sex addiction” may be influenced by unique cultural issues reflecting United
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32 States’ values about sexuality, and the fact that it has greatest prominence in the United States
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35 [7]. Review of these cases is presented as they reflect examples of administrative law, criminal
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37 law and civil law.
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41 Frequency of Forensic use of “sex addiction”
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45 It is difficult to obtain an accurate assessment of the frequency of the use of “sex
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47 addiction” in legal cases. Many lower-level proceedings at state-court level are not recorded at a
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detailed level sufficient to identify specific diagnostic claims and moreover, proceedings
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52 involving family law matters (e.g., divorce) are often closed to parties not directly involved in
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54 the case. Even at the appellate levels, issues such as allegations of “sex addiction” may only be
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57 referenced in court decisions if they are deemed relevant to the questions under appeal. With
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59 these parameters, the cases identified in legal databases likely under-represents the prevalence of
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4 actual cases where “sex addiction” has been applied in some aspect of the legal proceedings in
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7 lower levels. While certainly not exhaustive, Google Scholar was used as a search mechanism
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9 given it is easily accessible using the term “sexual addiction” which yields 210 results, dating
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12 back to 1990. Interestingly, a similar numbers of cases for related terms in more formal legal
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14 databases such as Lexis-Nexis or WestLaw was also noted. These different databases each
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17 include various levels of details, annotations and headnotes. However, for purposes of simple
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19 identification of US caselaw involving “sex addiction”, this current search strategy appears a
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21 reasonable strategy to further this current review. However, this review cannot be considered
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24 exhaustive.
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Review of these cases suggests that while forensic claims of “sex addiction” span across
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30 various legal cases, they are predominantly occurring in criminal, civil law, including family law
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32 matters, and administrative law. We first introduce the cases under their respective legal domains
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35 and then we will offer commentary about our general observations.
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Administrative Law
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42 Administrative law includes rules and regulations governing the licensing and
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45 certification of professional practices such as medical providers and lawyers. In many
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47 jurisdictions, governing boards take issues of mental health and substance use disorders into
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consideration, with sanctions, restricted licenses and monitored treatment for professionals.
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52 Parker reported that 48% of the non-substance addictions reported by state bar associations to the
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54 American Bar Association involved “sex addiction” [8]. Some examples are noted below.
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4 Example 1: The medical license of J.T.., a Washington state anesthesiologist, was suspended,
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7 following his own self-report to the Board that he had fondled the breasts of multiple female
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9 patients, while they were sedated. J.T. self-reported this information to the Board, while he
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12 “voluntarily underwent long-term inpatient treatment for sex- addiction.” The Board noted that:
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14 “While Respondent’s efforts to get treatment for his addiction issues is laudable, the behavior he
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17 admitted to is so egregious and harmful to patients that he cannot practice with reasonable skill
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19 and safety [9].”
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23 Example 2: In 2009, Illinois District Attorney K.K. prosecuted a man for severe domestic
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25 violence. During the trial, K.K. sent numerous sexually-charged text messages to the ex-
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girlfriend and victim of the defendant. K.K. resigned when the scandal became public, but was
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30 sued by the victim in 2012, where he testified that “untreated “sex addiction”” had contributed to
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32 his actions. In court, K.K. asserted that he had a “sexual addiction,” allegedly triggered by
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35 abused medications. During testimony, he argued that “sex addictions” were similar to eating
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37 disorders, and not seen as legitimate due only to social stigma. In 2014, his license to practice
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40 law was suspended by the Illinois Supreme Court [10].
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43 Example 3: In November 2014, the medical license of S.D., a New Mexico obstetrician was
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46 suspended.[11] Action toward his license was subsequent to allegations that he had sex with
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48 multiple patients, performed medical procedures under the influence of alcohol, and was
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51 deficient in his medical care of patients he had admitted to hospitals. He allegedly failed to
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53 attend the birth of one patient, as he was engaged in sexual intercourse with another patient at the
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56 time. Though problems with alcohol were noted in the Board’s documents, concerns with his
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58 sexual behaviors appear to be prominent in the Board’s actions. In January of 2015, Dr. D. was
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4 ordered by the New Mexico Medical Board to receive evaluation and treatment at a “sex
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7 addiction” treatment facility in Los Angeles. Decisions about ongoing licensure and professional
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9 activity were to be made subsequent to this evaluation [12].
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13 In the administrative law cases reviewed, “sex addiction” is often offered as a mitigating
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15 factor by individuals seeking to preserve their occupational licensing. Licensing boards appear to
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18 vary in their acceptance of these arguments. However, in some reviewed cases, individuals have
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20 been ordered into “sex addiction” treatment, as a component of their ongoing monitored
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23 treatment and board-sanctioned assistance. Licensing boards of various professions may
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25 recommend different types of treatment or interventions, and it appears that in cases of sexual
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behaviors, referral to mandated “sex addiction” treatment is often considered an administrative
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30 option. This review found little to no evidence that such administrative bodies consider the lack
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32 of evidence of efficacy in such treatment programs. It is possible that such bodies may view “sex
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35 addiction” treatment as the only intervention response in such cases.
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Civil Law
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42 Civil law concerns legal relationships between persons and entities, and is distinct from
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45 criminal law or administrative regulations. For purposes of this discussion, relevant civil law
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47 addresses lawsuits for damages.
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51 Example 1: J.E. began outpatient treatment in the state of Washington with marriage and family
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53 therapist Dr. T., following an inpatient hospitalization for treatment of drug and alcohol
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56 addiction. Shortly after beginning treatment with J.E., Dr. T. initiated individual and occasional
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58 marital therapy with the couple and their two children as well. Dr. T. described J.E. to his wife,
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4 and to others, as a “sex addict,” though in court, the therapist “admitted the need to use great care
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7 in diagnosing “sex addiction,” using standardized screening instruments and diagnostic criteria.
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9 She testified that "[e]very patient that comes in with a sexual addiction statement of need" is
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12 given 10 screening questions and a 30-page document to fill out. Dr. T. admitted administering
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14 none of those tests to J.E. prior to her reaching her conclusion that he was a sex addict.” J.E. and
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17 his wife filed malpractice claims against Dr. T., after the therapist filed unsubstantiated reports of
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19 child sexual abuse against J.E.. The couple later divorced and an expert witness “testified that
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21 Dr. T. did not meet the standard of care and that her “misdiagnosis and the application of wrong
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24 therapeutic errors . . . is the proximate cause for the destruction of their marriage [13].”
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26 Licensing complaints filed against Dr. T. led to restrictions being placed on her clinical license,
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29 along with requirements that she complete additional training [14].
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32 Example 2: In July 2013, Tennessee attorney C.S. filed suit against computer company Apple,
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35 asserting that the company’s failure to install filtering software on its devices and warn of the
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37 dangers of pornography, had led to C.S.’ “lifelong pornography addiction.” Further, C.S. alleged
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40 that Apple’s negligence and his pornography addiction had led to severe emotional distress, a
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42 failed marriage, and hospitalization for treatment of his condition [15]. The following year, C.S.
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45 filed suit attempting to intervene in a Florida marriage equality case, seeking the right to legally
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47 marry his “porn-filled Apple computer [16].” C.S. argued that addiction had led him to prefer sex
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with his computer, rather than a real woman, and that he was attempting to protect the rights of
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52 those, like him, who had fallen prey to these addictive processes. C.S.’ legal license was
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54 suspended in 2011 due to “mental infirmity,” but this did not deter him from pursuing self-
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57 directed legal actions. Though both of these legal actions were ultimately dismissed, in 2014,
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59 C.S. reportedly began pursuing similar involvement in Utah’s marriage equality challenges.
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4 Example 3: In 1996, multiple incarcerated sexual offenders sued the State of New Mexico,
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7 alleging that the State’s failure to adequately treat their sexual addiction constituted violations of
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9 their civil rights. States have a duty to provide medical care to inmates, and the plaintiffs argued
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12 that they were “driven by sexually compulsive drives that are deviant,” which had not been
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14 adequately treated or recognized by the State’s correctional system. The suit asserted that “sex
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17 addiction” was a legitimate, accepted disorder according to numerous medical journals, and that:
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19 “addictive sexuality erodes his self-esteem to [the] point of apathy, reinforces fear and feelings
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21 of differentness, leading to apathy, and keeps him in the `addictive cycle.'” Because the mental
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24 health conditions alleged by the inmates were not “serious” in nature, had not been diagnosed by
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26 licensed physicians, and there was no evidence these concerns had been ignored by the State, the
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29 lawsuit’s claims were ultimately dismissed [17].
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32 The construct of “sex addiction” in civil law proceedings is utilized in many different
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35 fashions, pursuant to the strategies of plaintiffs seeking legal recourse. In some cases, “sex
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37 addiction” is included in claims which are seen as relatively frivolous. In others, there are claims
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40 of malpractice against professionals who may engage in apparently unethical practices as they
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42 utilize “sex addiction” concepts and treatment strategies.
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46 Family Law
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“Sex addiction” is an increasingly common complaint in family law, related primarily to
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52 matters of child custody and divorce proceedings. An article published in the Wisconsin Law
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54 Journal describes the role of “sex addiction” in family law, citing indirect risks posed to children,
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57 through neglect or exposure to sexual material, and recommending “sex addiction” treatment.
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59 The article did not acknowledge the paucity of data regarding “sex addiction” treatment [18], and
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4 lack of legal precedent regarding “sex addiction” was described as being due to legal reluctance
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7 to deal with sexual issues and people’s desires to keep their sexual issues private [19].
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Example 1: In 1999, P.K. and M.K. were married in Delaware. In 2010, P.K. confronted M.K.
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13 about his extramarital sexual activities and he confessed to patronizing prostitutes over the past
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15 several years. The couple divorced in 2011. During this period, M.K. began attending “sex
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18 addiction” group treatment. P.K. filed for sole custody of their son, alleging that her ex-
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20 husband’s “sex addiction” put their son at risk. She argued in court that M.K. had exposed their
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23 son to harm, by virtue of his participation in “sex addiction” treatment with registered sex
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25 offenders, and by taking their son on an outing with other group members who may have
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included sexual offenders. A psychological evaluation of M.K. was conducted, which
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30 recommended that the court may wish to supervise and monitor M.K.’s treatment for sex and
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32 drug addiction, to ensure the child’s safety, but did not indicate that M.K. posed a risk to the
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35 child. Ultimately, the court asserted that M.K.’s “sex addiction” was not conclusively proven,
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37 and that there was no evidence that M.K. posed a risk to his son. P.K.’s request for sole custody
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40 was denied [20].
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43 Example 2: R.P. and A.P. married in 1995 in Kentucky. They had two children, but separated
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46 and divorced in 2003. In custody proceedings, A.P. alleged that R.P. was a sexual addict, who
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48 had purchased a “sex addict self-help workbook” at one point, had admitted that he had a
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51 problem with pornography and credit card debt related to this problem, and that he had once
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53 taken a nonconsensual nude picture of A.P. in the shower. R.P. was once cited for “loitering for
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56 the purposes of prostitution,” with a known prostitute in his car. These charges were ultimately
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58 dropped. As R.P. was a high school music teacher, this matter was considered, but not acted
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4 upon, by state and local educational and school boards. Courts ultimately awarded sole custody
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7 to A.P., on the basis of their concern for the children’s best interests. [21].
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Example 3: In 2007, R.J. petitioned for divorce from her husband S.J., on grounds of habitual,
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13 cruel and inhuman treatment. Her husband’s sexual behaviors and attitudes, allegations of
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15 infidelity, and claims of pornography and sexual addictions were central to the petition. S.J.’s
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18 desire for oral and anal sex from his wife was a contentious issue for the couple. They reportedly
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20 had sex about three times a week, though S.J. wanted sex more frequently. A court opinion
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23 noted: “There was no evidence that he raped or sexually battered [R.J.]. There were no
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25 allegations of domestic violence. Despite [S.J.]'s whining, complaining, coercive and boorish
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behavior, [R.J.] consented to each and every sexual act in their marriage.” Regarding [SJ]’s use
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30 of pornography, court opinions stated “[R.J.] claimed that [S.J.] was addicted to pornography,
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32 but she testified that she had not seen any pornographic videos in the home in over five years.
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35 More importantly, [R.J.] also testified that earlier in the marriage she participated in watching
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37 pornography with [S.J.].” The couple separated in 2004 due to financial problems related to
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40 S.J.’s gambling. S.J. attended residential treatment for gambling problems at a Mississippi
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42 addiction treatment program. While there, S.J. completed a “sex addiction” Screening Test, and
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45 was told he should stay an additional ten days to deal with his sexual addiction issues. S,J,
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47 declined to stay the additional period and was never formally diagnosed or treated for “sex
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addiction.” Ultimately, courts granted R.J.’s petition for divorce, and supported her allegations of
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52 “cruel inhuman” treatment as justification for the divorce.[22]
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56 The construct of “sex addiction” has a mixed reception by courts in family law
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58 proceedings. It appears to be most often included as a component of efforts to present a negative
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4 and unsafe image of one parent or another. In divorce and custody cases, distinct from other legal
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7 proceedings, “sex addiction” appears to be rarely invoked in an exculpatory fashion.
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Criminal Law
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14 Criminal law considers violations of law subject to penalty by governing jurisdictions. In
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17 cases related to sexual offenses, criminal law and civil law often intersect, as convicted sexual
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19 offenders may be civilly committed as dangerous, due to mental illness. Further, sexual offenders
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are subject to public registration requirements. United States Sentencing Guidelines recommend
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24 that an individual’s ability to control their behavior should be taken into consideration by the
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26 courts as they sentence, with evidence of impaired control supporting decreased sentences. Some
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29 defendants have presented behavioral addictions-related testimony to support their claim that
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31 they had diminished behavioral control [6]. Criminal defense attorneys sometimes explicitly
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34 identify “sex addiction” as a potential defense for sexual charges, particularly in cases of child
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36 pornography. One attorney’s website lists out several possible defenses against charges of child
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pornography, and includes “sex addiction” amongst them: “Addiction — Although not a true
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41 defense, if you can offer psychological testimony that you are addicted to the material and show
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43 the appropriate remorse, you could persuade the judge to give you a lenient sentence and
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46 undergo counseling as a condition [23].”
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Example 1: In 2011, W.V., a 25 year-old graduate student, set up a hidden camera in the
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52 bathroom of a California coffee shop He recorded several days’ worth of video of women,
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54 including underage females, as they used the restroom. That same month, W.V. broke into the
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57 apartment of several college-age females, taking underwear, tampon applicators, and personal
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59 information. W.V. was arrested after an employee of the coffee shop noticed the hidden camera
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4 and notified police. W.V. was identified in store security camera recordings. Upon arrest, W.V.,
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7 described to police that he had a “fetish” for women using the restroom and admitting
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9 masturbating with the videos and materials he had stolen. After arrest, W.V., saw a clinical
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12 psychologist who referred him to a “sex addiction” treatment facility in Los Angeles. He
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14 received treatment from a psychologist and certified “sex addiction” therapist for several months,
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17 including an “intensive” ten day program. The psychologist described that W.V. had a history of
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19 depression and isolation prior to the sexual crimes, and reducing this social isolation was a major
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21 component of treatment. W.V., was later assessed and treated by a psychiatrist, who diagnosed
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24 him as suffering “compulsive sexual behavior, major depressive disorder, and social anxiety
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26 disorder.” The treating psychiatrist testified that after treatment, W.V. had a high level of
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29 motivation to “stay in recovery,” and that “His behaviors, in my opinion, were a direct result of
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31 untreated symptoms of compulsive sexual behavior.” A second forensic psychiatrist also
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34 evaluated W.V. and later testified that W.V.’s, sex addiction, was in remission.”
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37 California state law stipulates that in order to require lifetime registration as sexual
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40 offenders, "[T]he trial court … must find whether the offense was committed as a result of sexual
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42 compulsion or for purposes of sexual gratification, and state the reasons for these findings [24]."
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45 W.V. was required by the courts to register as a sex offender, and appealed the decision, arguing
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47 that the Court did not take into consideration his “zero risk” for reoffending, by virtue of his
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successful treatment. An appeals court upheld the decision, noting that it was significant that the
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52 prosecution offered no evidence that contradicted the opinions of the clinical professionals who
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54 treated and evaluated W.V. . Despite evidence of numerous paraphilic behaviors (voyeurism,
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57 specific/object fetishism) there is no record in court documents that W.V. was diagnosed with a
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59 paraphilia, or treated for same. Risk of reoffending and treatment, as described in court records
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4 of testimony, were based on the case formulation as a “sex addict” with depression and anxiety,
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7 as opposed to an individual with a diagnosable sexual paraphilia [25].
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Example 2: W.I. was a Florida businessman in the construction industry, arrested in 2006
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13 connected to charges of child pornography. Since 2001, W.I. had been traveling throughout Asia
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15 associated with business trips, and spent weekends on trips to brothels which specialized in
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18 underage children. While there, W.I. would photograph the children and himself. He later
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20 distributed these photographs using the Internet, which led to his arrest. W.I. engaged in
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23 sadomasochistic behaviors with these children, and with other prostitutes for much of his adult
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25 life. The prosecution anticipated that the man’s defense might include an attempt to blame his
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behaviors on mental illness or addictive behaviors, and cited precedent “[M]ost people who
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30 collect a sizeable amount of child pornography are in some way addicted to collecting it [26].”
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34 Prior to trial, W.I. attended a residential treatment center in Florida, where he was treated for
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36 “alcohol abuse problems and sexual addiction.” W.I. was evaluated by a psychiatrist, and a
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psychologist. The psychiatrist diagnosed W.I. with pedophilia. In contrast, the psychologist’s
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41 psychosexual report suggested W.I.’s behaviors “could be described as a `sexual addiction,' with
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43 many behaviors and an obsessive fixation which included frequent masturbation, anonymous sex
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46 with prostitutes and the eventual use of brothels in Cambodia.” The psychologist described W.I.
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48 as “sexually obsessed for at least the last ten years,” and stated during trial, that W.I. had “a long-
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51 standing problem with sexual obsession,” “something like sexual addiction,” and …"obsessive-
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53 compulsive type disorder, not the full-blown disorder, but with the sexual behavior being the
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56 most prominent feature.”
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4 In a letter W.I. wrote to the district court a week before sentencing, W.I. admitted to his
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7 actions and acknowledged their wrongness adding “but it was to[o] late, my “sex addiction” was
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9 now in full control of me.” W.I. was initially sentenced to 17 and a-half years in prison, but the
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12 sentence was appealed by prosecutors. The Federal Appeals Court held that the judge in the
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14 initial trial had been inappropriately swayed by testimony about W.I.’s personal philanthropy,
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17 and by testimony about W.I.’s impaired ability to control himself. After appeal, W.I. was
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19 sentenced to the maximum sentence, thirty years in Federal prison [27].
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23 Example 3: In Raleigh, North Carolina, J.W. faced the death penalty as he stood trial for the
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25 rape and murder of a prominent local figure, K.T., a member of the state board of education. Part
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of the defense strategy was to paint J.W. as a sex addict, who was acting out of control, driven by
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30 sex desires that he was powerless to resist. A social worker and “sex addiction” specialist
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32 testified that J.W. had earned an “18 on a 20 point-scale” measuring “sex addiction,” and that he
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35 was one of the most severe sex addicts she’d ever seen. A psychiatrist testified that he had
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37 treated J.W. for mental and alcohol problems, but had been unaware of any sexual issues. J.W.’s
38
39
40 defense attorneys argued that because of his “sex addiction” and other disorders, their client had
41
42 diminished capacity when he committed these crimes, and thus should not be held fully
43
44
45 responsible for his actions. The jury in the case voted unanimously for a life sentence, and J.W.
46
47 was sentenced to life in prison without parole [28].
48
49
50
51 A telephonic interview for this article was conducted of two of the North Carolina
52
53 prosecutors who led the prosecution of Jason W. [29] These attorneys reported that they did not
54
55
56 actively attempt to discredit or invalidate testimony about “sex addiction,” as a part of their
57
58 overall legal strategy. “Paying too much attention to it would have given it more
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2
3
4 credibility…The defense counsel threw lots of things out there, from drug addiction to mental
5
6
7 illness and “sex addiction,” just trying to get something to stick.” The attorneys interviewed
8
9 acknowledged that there was substantial evidence of treatment for mental illness prior to the
10
11
12 crime, though they believed the mental health history was “broad but not deep,” and did not
13
14 reflect diminished capacity of the severity argued by defense. On the basis of this history of
15
16
17 treatment, they believed early on that they would be unlikely to achieve the death penalty in the
18
19 case. During cross examination of the “sex addiction” therapist, the prosecutors questioned her
20
21 about both diagnosis and testing and the therapist testified that although “sex addiction” was not
22
23
24 currently a formal diagnosis, DSM 5 was expected to include the disorder. She acknowledged
25
26 that the tests she used to diagnose “sex addiction” were “unregulated.” The attorneys interviewed
27
28
29 were surprised to learn during interview that “sex addiction” had not in fact been included in
30
31 DSM5.
32
33
34
35 Criminal law cases include some of the most serious and concerning uses of the “sex
36
37 addiction” construct. These cases reflect extremely serious, violent criminal acts, with the most
38
39
40 serious legal penalties, up to and including the death penalty. Under these circumstances, it is
41
42 perhaps understandable that “sex addiction” may be invoked in desperate efforts to mitigate
43
44
45 punishments. Similarly, prosecutors seeking to protect communities from defendants seen as
46
47 highly dangerous may also utilize claims of “sex addiction” in order to paint defendants in the
48
49
50
worst possible light.
51
52
53 Conclusion
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55
56
57 A number of interesting issues arise with respect to the cases we have reviewed in the
58
59 present article. It would appear that the line between sex offending and “sex addiction” needs
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2
3
4 more clarity. Although it’s possible for dysregulated sexual behavior to exist concurrently with
5
6
7 sex offending behavior, several of the cases cited appear to misapply an “addiction” model to sex
8
9 offending behavior. Such confusion can lead to recommending treatment that is contra-indicated
10
11
12 (e.g. someone with sex offending behavior ordered into treatment for “sex addiction,” as opposed
13
14 to referral to empirically-supported sex offender treatment). Additionally, in cases of family law,
15
16
17 this may have ramifications for child custody and parental visitation rights, particularly if
18
19 children at risk are deemed safe due to misdiagnoses.
20
21
22 The lack of clear operationalized criteria and universal agreement about “sex addiction”
23
24
25 allows for claims that one is addicted to sex as an explanation for a referred offense which may
26
27 be inaccurate or one step removed from the “real” problem. For example, if the effects of drugs
28
29
lead to dysregulated sexual behavior, then substance-abuse might be the more parsimonious
30
31
32 explanation rather than “sex addiction.” Moreover, abuse of a “sex addiction” label may emerge
33
34 in family law where communication problems, a lack of emotionally intimacy, or sexual
35
36
37 incompatibility may be miscategorized as “sex addiction.” This could lead to faulty judgments in
38
39 family law cases with their associated consequences for the non-prevailing party.
40
41
42 Some attorneys may erroneously conclude that the claim of mental health illness (e.g.
43
44
45 “sex addiction”) as a defense will somehow reduce sentencing or elicit compassion from the
46
47 court leading to more lenient sentencing. Some of the cases cited in this article clearly illustrate
48
49
50 abuse of the “sex addiction” concept as a mental illness as part of a legal strategy with little
51
52 understanding of what constitutes mental illness, let alone, sexual behavior problems. Courts
53
54
55
should be encouraged to understand that at the present time, “sex addiction” is not a sanctioned
56
57 disorder or mental illness and thus it does not receive the same recognition or privileges as
58
59 disorders contained in the DSM-5. This may affect the degree to which testimony related to “sex
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2
3
4 addiction” is seen as helpful in determining a person’s level of self-control, responsibility, or risk
5
6
7 of re-offending.
8
9
10
11
Despite claims that the concept of “sex addiction” may hold little real risk for forensic
12
13 misuse [4], the current review finds a number of examples where “sex addiction” has played a
14
15 significant role in legal proceedings of many types. In the current review, it is unclear to what
16
17
18 degree claims of “sex addiction” are truly influencing court decisions. However, it is difficult to
19
20 determine whether this inconsistent reception by courts is due to the ways in which the “sex
21
22
23 addiction” construct is used, or due to legal skepticism regarding the notion that sex constitutes
24
25 an addictive disorder, which in part is justified. In many cases, the concept has been misused.
26
27
28
However, it must be recognized that a thorough assessment of the frequency of such claims may
29
30 be impossible, due to limitations on data collection in US courts. Nevertheless, our limited
31
32 review suggests that “sex addiction” is playing an increasingly significant role in many different
33
34
35 types of forensic matters. The legal response to “sex addiction” has not been universally
36
37 negative, or positive. This inconsistent response increases the chances that plaintiffs and
38
39
40 defendants will continue to utilize the “sex addiction” strategy in future cases, at least until either
41
42 the legal system develops a consistent stance.
43
44
45
46 Current standards of legal proceedings regarding the admissibility of scientific
47
48 information related to mental health do exist. These rules require that scientific testimony be
49
50
51 based on research that is repeatable, involves testing of hypotheses, with real world data, using
52
53 sound science, and upon research and scientific information that is generally accepted [30].
54
55
56 Whether testimony related to “sex addiction” fulfills these criteria does not appear to have been
57
58 tested in legal proceedings. Colasurdo recommended that “in the eyes of the law, the concept of
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4 addiction should be restricted to chemical substance dependence,” and that the unsettled,
5
6
7 unreliable and contentious nature of this field “is likely to have an unjustified distorting effect on
8
9 the law [6].”
10
11
12
13 In the cases reviewed, there are several instances where the legitimacy or validity of
14
15 claims of “sex addiction” have been directly questioned or challenged on the basis of their
16
17
18 acceptance as a formal diagnosis. Allen Frances, MD., a former editor of DSM-IV and a vocal
19
20 critic of the American Psychiatric Association’s DSM 5 process [31] has testified in one
21
22
23 California civil commitment case, specifically against the use of a “sex addiction” diagnosis.
24
25 Frances argued that promiscuity was not a mental disorder, and asserted that “Compulsive
26
27
28
sexuality is ‘an incompetent diagnosis in a forensic case,’ and a psychologist who would offer
29
30 such a diagnosis as an expert opinion should not be taken seriously [32].” Where research and
31
32 theory are unclear, as with “sex addiction,” expert testimony and evidence related to mental
33
34
35 health diagnosis or treatment should acknowledge that lack of empirical clarity. Legal standards
36
37 regarding expert testimony in such matters limit the degree to which experimental or developing
38
39
40 science can be utilized or accepted as evidence. [30]
41
42
43 Even where courts appear to have questioned the validity of “sex addiction,” they have
44
45
46 typically used administrative procedures to exclude the question of “sex addiction,” rather than
47
48 making determinations on the legitimacy of these claims. No cases were identified in this review,
49
50
51 where testimony related to “sex addiction” was subjected to evidentiary proceedings to
52
53 determine whether they met criteria for admissibility as scientific evidence. It is possible that this
54
55
56 is an intentional strategy by courts, in order to “dance around the concept” due to legal issues
57
58 such as the exclusion of conditions including sexual problems from laws such as the Americans
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 1
2
3
4 with Disabilities Act [6]. The social acceptance of the concept of “sex addiction” seems to have
5
6
7 resulted in a growing presence of the concept of “sex addiction” in legal proceedings throughout
8
9 the United States. Although it appears that attorneys may be aware that “sex addiction” is not an
10
11
12 accepted diagnosis, it is often included in cases as a part of overall legal strategies. Though
13
14 courts are thus far often resolving cases without formally addressing the question of “sex
15
16
17 addiction,” the prevalence of this issue raises questions about effective use of court and systemic
18
19 resources on a diagnosis not currently supported by modern medicine.
20
21
22
23 The label of “sex addiction” is used both punitively, and in an exculpatory manner in
24
25 forensic cases. The label of sex addict is used by both plaintiffs and defendants, to assert or
26
27
28
imply that an individual’s sexual behaviors are out of their control, to excuse their choices, or to
29
30 establish them as likely to continue such behaviors. Despite the belief that “sex addiction” is
31
32 “uncontrollable,” research with self-identified sex addicts has suggested that they are no less able
33
34
35 to exert control of their sexual arousal than are non sex-addict counterparts [33]. Many anecdotal
36
37 descriptions of “sex addiction” suggest that sex addicts demonstrate difficulties with impulsivity,
38
39
40 cognitive rigidity, emotional dysregulation and other forms of executive functioning. While
41
42 research certainly supports comorbid psychopatholgy with “sex addiction,” conceptualizing it as
43
44
45 a brain disorder (e.g. executive deficits) or a problem of generalized impulse control does not
46
47 appear to be supported in well-designed studies. [34, 35]. Where questions of self-control are
48
49
50
central to a legal case, research and theory regarding “sex addiction” may not be as helpful to the
51
52 courts, as research and diagnoses related to impulse control disorders or other diagnoses where
53
54 there is a greater body of empirical research. Testimony related to claims of “sex addiction”
55
56
57 should then be grounded by extant empirical research.
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 1
2
3
4 For patient well-being, it is extremely important that medical and mental health
5
6
7 interventions be based upon the most accurate, up to date scientific evidence possible. Given the
8
9 powerful influence that medical and mental health practice plays in legal realms, it must be
10
11
12 informed and moderated by acknowledgment that cultural and social biases can intrude into
13
14 medical practices, in harmful and destructive ways. The history of American medicine is replete
15
16
17 with examples where sexual issues such as recovered memory of sexual abuse, and
18
19 homosexuality were treated in ultimately damaging ways by the medical and mental health
20
21 fields, based upon poor science.
22
23
24
25 Given the many questions and concerns about the concept of “sex addiction” and related
26
27
28
formulations, it is important that the role of “sex addiction” in legal proceedings be critically
29
30 examined. Because “sex addiction” is often accepted and endorsed in the general media, and
31
32 because attorneys are mostly concerned with the outcome of cases, it is understandable that court
33
34
35 proceedings may be faced with addressing the legitimacy of this concept. It remains to be seen
36
37 whether, in the long run, claims of “sex addiction” and related concepts, will prove useful in
38
39
40 court cases, or whether they will be regarded as fruitless efforts, and abandoned as an ineffective
41
42 legal stratagem.
43
44
45
46 It is essential that mental health professionals, forensic psychologists and psychiatrists,
47
48 sex offender therapists and sexologists, all endeavor to educate the courts about these questions
49
50
51 and concerns, when “sex addiction” claims or labels are presented in court. Where professional
52
53 licensing boards are involved, it seems appropriate and judicious for these groups to make
54
55
56 decisions about both impairment and treatment, upon the most current, accurate empirical and
57
58 medical evidence available. Accurate, ethical testimony based upon the most current medical
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 1
2
3
4 diagnostic framework and research preserves judicial effectiveness, the credibility of clinical
5
6
7 testimony, protects victims and ensures that individuals are held responsible for their behaviors,
8
9 and offered the most current and effective treatments.
10
11
12
13 Compliance with Ethics Guidelines
14
15 Conflict of Interest
16
17
18 David J. Ley has testified as an expert witness in legal cases related to “sex addiction,” has
19 received royalties from Rowman & Littlefield Publishers, is a paid blogger/writer for Psychology
20 Today, and has had travel expenses covered by various media outlets for appearances on
21
television shows.
22
23
24 Julie Brovko, reports no relevant disclosures.
25
26 Rory Reid, was the principal investigator for the DSM-5 field trial on hypersexual disorder. He
27
28
receives funding from NIMH grants, consulting with universities and mental health agencies, and
29 has been compensated for writing mental health related articles for various websites. He has
30 received honorariums or financial compensation for providing training or research consulting
31 related to hypersexual behavior and gambling disorders from domestic and foreign government
32 entities.
33
34
35 Human and Animal Rights and Informed Consent This article does not contain any studies
36 with human or animal subjects performed by any of the authors.
37
38
39
40 References
41
42 Papers of particular interest, published recently, have been highlighted as:
43
44
45 • Of importance
46 •• Of major importance
47
48
49
50 References
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52 1. American Psychiatric Association. Diagnostic and Statistical Manual of Mental Disorders.
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56 2. Ley D, Prause N. Finn P. The emperor has no clothes: A review of the pornography addiction
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 **Reid RC, Kafl(a MP. Controversies about hypersexual disorder and the DSM-S. Current
mdofitfiwaH

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UTwaHOOW\IO‘sU‘IbWMI—‘OKOGDQONU‘In-bUJNI—‘OkomdmmmeHOWWQOWU'IwaI—‘OKDGDQONU‘II-bUJNI—‘Oko
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mmfi‘smmmU‘lUWU'lU‘lU‘lUTU'IU‘IU'IUT|J>ybbbbhubdbb.bpbwwwwwwmwwwwmNMNNMNNNI—‘I—‘I—‘I—‘I—‘I—‘I—‘I—‘I—‘H

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12 20. Kraft v. Kraft, Del: Supreme Court 2011
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