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Mental Health Experts in Employment and Medical Malpractice Litigation
MENTAL HEALTH EXPERTS IN
EMPLOYMENT AND MEDICAL MALPRACTICE LITIGATION
Robert T. M. Phillips, M.D., Ph.D., F.A.P.A.
FORENSIC CONSULTATION ASSOCIATES, INC.
1726 DEACON WAY
ANNAPOLIS, MARYLAND 21401
TELEPHONE: 410.757.6797
FACSIMILE: 410.757.6799
Each year I am asked to participate in several workshops on the use of mental health experts in
employment and medical malpractice litigation. The following summarizes the best of what I
have learned from the presentations of fellow panelists and, most importantly, from my years of
practice and experience in the field of forensic psychiatry.
There are no more dangerous waters to navigate in the world of forensic psychiatry than the
provision of consultation and expert testimony in employment or medical malpractice litigation.
Lawyers and psychiatrists intellectually and professionally operate within different paradigms.
The law tends to be reductionisticly black or white. Medicine and in particular psychiatry tends
to be a pattern of grayscales. Generally the two, when interfaced, are like the proverbial oil and
water metaphor. When handled with care, the relationship can be synchronous like salad
dressing - if not it can be as disastrous as an oil spill!
While psychiatrist and psychologists are generally better trained and therefore more likely
qualified to testify about mental disorders than other mental health professionals they hardly
have exclusivity in the forensic arena. Caution should be exercised in selecting an expert paying
careful attention to actual expertise. The following brief guide to background and training is
illustrative of the significant differences among mental health professionals:
MENTAL HEALTH EXPERTS
PSYCHIATRIST
M.D.
4 years college
4 years medical school
1 year internship
3 years residency
1-3 year’s fellowship training in subspecialty field (i.e. child psychiatry, geriatrics,
Licensure as Physician and/or Surgeon
Optional:
Board Certification
Added Qualifications
Fellow, American Psychiatric Association (F.A.P.A.)
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PSYCHIATRIST
D.O.
4 years college
4 years osteopathic medical school
1 year osteopathic internship
3 years residency
1-3 year’s fellowship training in subspecialty field (i.e. child psychiatry, geriatrics,
Licensure as Physician and/or Surgeon
Optional: Board Certification and Added Qualifications
CLINICAL PSYCHOLOGIST
Ph.D. or Psych.D.
4 years college
4 years graduate school
1 year internship
Licensure as clinical psychologist
Optional:
Board Certification
PSYCHOLOGIST
Ph.D. or Ed.D.
4 years college
4 years graduate school
PSYCHOLOGIST
Ed.D.
4 years college
4 years graduate school
PSYCHOLOGIST
Ed.M.
4 years college
1-2 years graduate school
PSYCHOLOGIST
M.S.
4 years college
1-2 years graduate school
SOCIAL WORKER
D.S.W.
4 years college
4 years graduate school including minimum of 1 year practicum if clinical social worker
Certification or Licensure if clinical social worker
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SOCIAL WORKER
M.S.W.
4 years college
2 years graduate school including minimum 1 year practicum if clinical social worker
Certification or Licensure if clinical social worker
SOCIAL WORKER
B.S.W.
4 years college
SOCIAL WORKER
Job classification in some public mental health systems - no degree required
CLINICAL NURSE SPECIALIST
R.N., M.S.N., C.N.S.
4 years college
4 years nursing school
1-2 years graduate school
1-2 years clinical practicum
Licensure in Nursing
Certification as an advanced practitioner
PSYCHOTHERAPISTS
The most confusing title you will run across in the mental health professions is “psychotherapist”
or “therapist”. Years ago psychotherapists were almost always psychoanalysts, that is
psychiatrists who did additional training in one of the psychoanalytic institutes focusing on a
particular analytic theory (i.e. Freud, Jung etc). The training involved being psychoanalyzed
oneself and then doing psychoanalysis under strict supervision (training analysis). It was
expensive and time consuming (daily analysis for a year or more). Today psychologists and
limited other mental health professionals are formally trained as psychoanalysts.
The term therapist is more ubiquitous and less specific. Anyone can claim to be a therapist
regardless of background or training. In fact, in many states, one may advertise in the yellow
pages as a “therapist” without any licensure at all. If you sit with a patient and “talk about their
problems you may view yourself and therefore maybe able to market your self as a therapist.
OTHER PROFESSIONALS
Finally, an ever-expanding array of care providers with greatly divergent backgrounds and
training requirements has also entered the fray. Family and Marriage Counselors, Alcohol and
Drug Rehabilitation Counselors, and the Clergy are illustrative examples. The practices of these
professionals are regulated in certain states by certification codified by training requirements.
For others, recovering from an addiction may be one’s only qualification.
Psychiatrists and clinical psychologists remain the primary experts relied upon for mental health
testimony.
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EMOTIONAL DISTRESS
Whether the claim emanates from sexual harassment, discrimination on the basis of age, race,
gender, or related employment tort claims, the clinical assessment of psychological damage is
the primary task of the expert. When a person is physically injured by an individual and a legal
cause of action ensues, the use of medical testimony in establishing the extent of injury, potential
limitations, incapacity’s and resulting disability seems fairly straight forward and causes little
angst for the litigators. The ambiguity of emotional distress in litigation, which requires its
identification, authentication, assessment and measurement may be more difficult to understand
initially, but its understanding is not elusive.
More often than not experts engage in intellectual contests supporting the litigator’s polar
positions on the presence or absence of emotional distress. In reality, there are very few
adversarial scenarios that do not cause some degree of mental anguish. In the employment law
arena, the clinician will best serve counsel by identifying that psychological pain that is
reasonable and expected in a given work related circumstance from that which originates and is
sustained by the alleged wrongful acts of an employer. Through careful examination of the
plaintiff a determination of the preexistence of a mental illness and/or the exacerbation of
preexisting conditions as either would relate to the complaint is essential to answering the
question of “induced” emotional distress. Employment records, collateral interviews of spouses,
coworkers and supervisors will likely result in greater accuracy in a diagnostic opinion.
INDEPENDENT MEDICAL/PSYCHIATRIC EXAMINATION
The conduct of a competent and reliable psychiatric examination should include a thorough
assessment of the Complaint, the presence of any acute illness, a comprehensive exploration of
the work-related allegations of personal, family, medical, employment and prior psychiatric
history and the performance of a mental status examination. The mental status examination
should assess the general presentation of the plaintiff, with specific focus upon the mental
faculties of state of consciousness, intellectual functioning, attention, concentration, speech,
orientation, mood and affect, form of thought, thought content, perceptions, judgement, and
memory.
Certain cases may require neuropsychological testing. This is particularly useful in helping to
identify organic syndromes, localizing organic pathology and discriminating between borderline
psychotic states. Neuropsychological testing is generally the province of clinical psychologists
who will report their findings to a psychiatrist or incorporate them into their own diagnostic
opinion if they are serving as the primary expert. Examples of the most commonly used
psychological tests are:
PSYCHOLOGICAL TESTS
Wechsler Adult Intelligence Scale (WAIS)
Minnesota Multiphasic Personality Inventory (MMPI-2)
Bender-Gestalt Test
Roschach test
Thematic Apperception Test (TAT)
Draw-a-Person Test
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Other sophisticated medical or neurological consultations and diagnostic tests may be
indicated such as:
BRAINWAVE STUDIES
Electroencephalograpy (EEG)
BRAIN IMAGING STUDIES
Structural Techniques
Computer Assisted Tomography (CT)
Magnetic Resonance Imaging (MRI)
Functional Techniques
Positron Emission Tomography (PET)
Single Photon Emission Computed Tomography (SPECT)
LABORATORY STUDIES
Blood Chemistries
Thyroid Function Tests
These are medical assessments and will be performed by the psychiatrist or by a
neurologist consulting to the psychiatrist.
DIAGNOSIS
Ultimately a qualified expert should be able to define the identified mental disorders
suffered by the plaintiff using the nomenclature of psychiatry as codified in the
Diagnostic and Statistical Manual for Mental Disorders DSM-IV. The multi-axial
diagnostic system should be applied in the context of the complaint as modified and
summarized by the following table prepared by the law firm of Richtel & Smith:
AXIS I Major Psychiatric Illness:
Do the alleged symptoms meet the DSM-IV criteria for the diagnosis?
Disorders of Thought - Psychosis; Disorders of Mood-Depression)
(i.e.
AXIS II Personality Disorders:
Early onset- Lifelong maladaptive personality traits. If present, what are they and
how do they influence the current clinical picture.
AXIS III Pertinent Medical Disorder:
How do they affect psychiatric diagnosis?
Do they pre-exist? Influenced by medications?
AXIS IV Psychosocial Stressors:
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Few psychiatric conditions have a single cause. This is the causation axis for
attorneys.
What are the various stressors currently operating in the litigant’s life? Is a
superseding
intervening psychological stressor present that breaks the chain of causation?
AXIS V Global Assessment of Functioning:
Assessment of functional impairment. Considers psychological, social and
occupational functioning on a hypothetical continuum of 0% (inadequate
information) to100% (superior).
Remember that diagnosis by itself is
meaningless. It is
the level of functional impairment that counts.
(after Smith, William J. 1996 )
In addition to diagnosis, a psychodynamic formulation should be provided by the expert
who integrates the clinical findings with the unique presentation and adaptive capacities
or lack thereof.
RETAINING AN EXPERT
Be clear of what you are looking for. By that I mean the requisite training and experience
to answer objectively the clinical and forensic questions not to give you the answer that
you seek. Determine whether you seek a trial consultant, potential expert or both. Your
expert may ultimately become the most important communicator of critical information
to a finder of fact or a jury, not to mention yourself. Make certain that the expert has
mastery not only of the specific subject area, but also a facility to communicate possibly
complex clinical material in a simple and understandable manner. Jargon is kryptonite to
a lay person. Make the effort to assess the background, education, training and
experience including lectures and publications of your expert with an eye toward
potential bias. Ask the tough questions of your expert before opposing counsel does.
Be wary of a litigant’s treating mental health professionals being used as an expert
witness. Therapeutic relationships are founded upon trust and advocacy for care.
Impartiality is a rare fruit from this vine rendering the credibility of the treater/expert
legitimately suspect.
Be wary of experts who are ready to give an opinion without having reviewed the
complaint, the employment record, or who do not seek to obtain collateral information
from a spouse or significant other, family, neighbors, coworkers, supervisors, or other
relevant persons who can shed light on the mental state of the litigant before and after the
alleged injury.
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Remember that experts like attorneys are expensive consultants. Maximize their use by
focusing your requests of them. The best expert is one who is willing to disappoint you
with his opinion but will never disappoint you with his standard of practice.
PSYCHIATRIC ISSUES IN MEDICAL MALPRACTICE
I. Boundary Violations
The best reference on this subject is that of Robert I. Simon, M.D, whose chapter in
Principles and Practice of Forensic Psychiatry is definitive. I have liberally relied upon
this chapter to organize the following commentary.
Treatment in psychiatric practice can be reductionistically viewed to consist of either
verbal (psychotherapy) or somatic (medication) procedures. Included in the somatic
treatment would be electroconvulsive therapy. Because therapists are of such varied
discipline, and training the ability to codify beyond such classifications as individual,
group, begins to take on more of a description of the technique rather than anything else.
For our discussion it may be easier to focus upon what should happen universally during
the therapeutic experience and of course what should not.
Perhaps the best way to conceptualize this discussion is to consider what is commonly
referred to as treatment boundaries in psychiatric practice. The concept establishes the
perimeters within which ethical and responsible treatment is to occur. The therapist sets
the boundaries that define and secure the professional relationship of the therapist with
the patient.
Simon describes psychotherapy as “the impossible task” He writes:
“ All psychiatric treatments, regardless of theoretical orientation, are based
on the fundamental premise that the interaction with another human being
can alleviate psychic distress, change behavior, and alter a person’s
perspective of the world (Simon and Sadoff 1992). Psychotherapy can be
defined as the application of clinical knowledge and skill to a dynamic
psychological interaction between two people for the purpose of
alleviating mental and emotional suffering. This principle also applies to
biological and behavioral therapies. (Simon 1990). There are no perfect
therapies and there are no perfect therapists.”
Treatment boundary violations then are those event in which a therapist clearly crosses
the line that demarcates acceptable and appropriate practice. They occur on a continuum
and usually interfere with the provision of good care to the patient. Boundary violations
usually occur when therapists use the patient or the therapy to act out their own conflicts.
As a result, patients may be misdiagnosed or receive inappropriate or useless treatment.
The patients’ original illness may worsen. Boundary violations represent deviations from
the standard of care, which make for the basis of a malpractice suit. Therapists who
create no boundaries or maintain idiosyncratic boundaries are likely to provide negligent
treatment and are likely to harm patients. Boundary violations may be construed as
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negligent psychotherapy. Such is usually the case in a sexual misconduct claim as well
as other suits alleging exploitation of patients.
The following “boundary guidelines” are commonly accepted by practitioners in the field
to provide a framework for psychotherapy that helps maintain the integrity of the
treatment process:
1)
2)
3)
4)
5)
6)
7)
8)
9)
10)
11)
Maintain relative therapist neutrality
Foster psychological separateness of patient
Protect patient confidentiality
Obtain informed consent for treatments and procedures
Interact verbally with patients
Ensure no previous, current, or future personal relationship with the patient
Minimize physical contact
Preserve relative anonymity of therapist
Establish a stable fee policy
Provide consistent, private and professional setting
Define time and length of session
These guidelines are predicated upon several guiding principles, the first and foremost of
which is that the therapist must refrain from obtaining personal gratification at the
expense of the patient, the so called “rule of abstinence” (Freud 1959). The rule of
abstinence give rise to the concept of “relative neutrality” which places the patients
agenda in a position of paramount importance and relegates the therapist to a position of
having to know their place and staying out of the patient’s life. Simply put, a therapist is
not a parent and does not have the role of making decisions for or vetoing decision of the
patient. If a therapist believes an otherwise competent patient is about to make a foolish
decision, their role should be limited to raising the questionable decision as a treatment
issue. It is appropriate to explore with, not to coerce or decide for the patient. The
obvious exception is in the case of an incompetent individual where such intervention is
necessary to protect the life of the patient or that of others because of acute mental
illness. At the other end of the spectrum are court ordered treatments such as those
designed to restore to competence solely for the purpose of execution (Phillips 1996).
Such activity is well defined by statute though not always fully understood by patients,
family members or even therapists.
The goal of therapy is to foster patient autonomy and self-determination. As a matter of
law, the doctor-patient relationship is fiduciary and with it arises a “duty of care” that is
implicit: not to use the patient for personal advantage. Finally, the Principles of Medical
Ethics with Annotations Especially Applicable to Psychiatry instructs: “A physician shall
be dedicated to providing competent medical service with compassion and respect for
human dignity.”
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II. Transference and Countertransference
Although these constructs originate historically from Freud and are a major criterion by
which psychoanalysis can be distinguished from other forms of psychotherapy, the
conceptual framework is seldom absent from any interaction of patient and therapist. As
such, a basic understanding of this phenomenon is useful particularly when considering
how and whether boundary violations have or are alleged to have occurred.
By Kaplan and Sadock’s definition,
“Transference is the unconscious feelings and behavior exhibited toward
the therapist that are based upon infantile wishes the patient has toward
parents or parental figures. The transference may be positive in which the
therapist needs to be seen as a person of exceptional character, worth and
ability; or it may be negative in which the therapist becomes the
embodiment of what the patient experienced or feared from parental
figures in the past. Negative transference’s can be expressed in highly
labile and volatile ways, especially I patients whose personalities are
described as borderline or narcissistic. Both situations reflect the patients
need to repeat unresolved childhood influences.”
In psychoanalytic psychotherapy, the task of the therapist is to interpret the transference
and to help the patient gain insight into their emotions and behaviors thereby increasing
their ability to live their lives based upon mature and realistic expectations rather than
irrational childhood fantasies. Whether you believe in this model or not, there is no
escaping the fact that patients are going to develop feelings about their therapists
consciously and unconsciously and those feelings have the potential to affect the
therapeutic relationship demonstrably.
Countertransference encompasses a broad spectrum of the therapists reactions to the
patient both conscience and unconscience reactions to the patient which may interfere
with the therapists ability to remain detached and objective.
Regardless of the type of psychotherapy or, for that matter, whether the patient is seeking
treatment because of issues largely in the remote past of the patient’s life or that which
seems to arise from current stresses and pressures, issues of transference and
countertransference loom and may give rise to therapist misconduct or false accusations
by the patient.
III. Therapist Patient Sex: Clinical Issues
Boundary Violations
Although every case of sexual misconduct is unique, a “typical” scenario described by
Simon (1989) details a progressive, increasingly damaging succession of boundary
violations:
•
Therapists position of neutrality is gradually eroded in subtle ways
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•
•
•
•
•
•
•
•
•
Therapist and patient address each other by first names
Therapy sessions become less clinical and more social
Therapist’s self-disclosures occur, usually about current problems and sexual
fantasies about the patient
Therapist begins touching patient, usually by hugs and embraces
Therapist gains control over patient, usually by manipulating her transference and
medication
Therapy sessions are rescheduled for the end of the day
Therapy sessions become extended in time
Therapist and patient have drinks.dinner after sessions; dating begins
Therapist-patient sex begins
Transference Exploitation
Patients who come to psychiatric treatment are vulnerable because of their emotional pain
and suffering. Often they have impaired decision-making and judgmental capacities.
Abuse of the transference by engaging in a sexual relationship with a patient is
negligence per se and is an ethical violation. Ethical standards concerning sex with
patients after treatment has terminated are evolving. The potential for exploitation
remains high particularly if termination occurred for the purpose of establishing a future
sexual relationship. Some states have moved to set statutory
prohibitionary periods following termination of therapy. Even though it may not be
determined illegal by statute for a therapist to have sex with a former patient it may still
be unethical. The dilemmas continue. To what extent does a former patient have the right
to associate with and to choose their sexual partner? Some patients marry their former
therapist. Therapist sex with a former patient presents complex ethical and legal issues.
IV. Intentional Torts
The following outlines are useful adaptations from the Harvard Board Review Course
Lectures in Forensic Psychiatry
1) False imprisonment (wrongful restraint, commitment)
a) Restraint or confinement of an individual with an intent to deprive the individual
of his or her freedom in an unjustified manner
b) Willful and without just cause
c) Physical force not necessary; deception is enough, as is apprehension of force
d) Example: (1) Threat to commit a voluntarily hospitalized, non dangerous patient
to a hospital if he does not remain and accept treatment (2) Commitment when
requirements are not met
e) Defenses: consent, good faith clinical judgement that the requirements were met,
statutory immunity, emergency
2) Battery
a) Intentional touching of another without their consent and without justification
b) Contact has to occur
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c) Example: Involuntary medication or restraint absent emergency
d) Defenses: consent, emergency
e) Criminal (with assault) or civil (with or without assault)
3) Intentional misrepresentation (deceit or fraud)
a) A false representation made by one person to another with intent to persuade the
other person to rely on the information and act in a manner that causes them harm.
b) Common element in other torts, e.g. battery
c) Example: (1) voluntary agreement to treatment with medication based upon false
statements of risks; (2) false statements made regarding diagnosis in an effort to
keep patient in treatment; (3) billing for non-sessions; (4) describing sex with
therapist as part of treatment.
V. Unintentional Torts: Negligence and Malpractice
Negligence
1) Elements of proof: the Four D’S
a) Dereliction of a
b) Duty which
c) Directly causes
d) Damages
2) Standard of care defined by custom and practice of other physicians with the same
training and theoretical orientation.
a) Locality rule (is it fading?)
b) Error in judgement is not enough
3) Duty: A changing concept
a) May be explicit(accepting patient into treatment) or implicit (driving on highway,
working in the ER)
b) To whom is it owed?
i) Original contractual notion
ii) Duty to third party ( Managed Care Organizations)
4) Direct causation
a) Causation in fact: The But For Test
b) Proximate or legal causation
5) Damages
a) Physical or emotional
b) Calculated as present value of lost earnings (including lost services) and pain and
suffering
Malpractice (Selected Psychiatric Issues)
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1) General comments
a) Often incorporates both intentional and unintentional torts
b) All four elements must be proved
2) Top six allegations of psychiatric malpractice according to the Risk Management
Foundation
1991-1994
a) Improper diagnosis and/or treatment
25%
b) Violation of rights
13%
c) Inadequate monitoring
11%
d) Sexual misconduct or undue familiarity
11%
e) Medication-related adverse outcomes
10%
f) Failure to insure safety
9%
3) Respondeat superior: Let the master answer
a) The "master” may be held liable in certain cases for the wrongful acts of the
servant
b) Acts must be within the scope of the employment
c) Clinical supervision is the most frequent source of such causes of action
i) Supervising residents or other trainees
ii) Medication backup
iii) Supervision of non-physicians
Caveat to Clinicians: “If you sign, the case is thine”- Thomas Gutheil, M.D.
4) Abandonment
a) Unilateral and unjustified termination of a doctor-patient relationship without
reasonable notice, which leaves the patient without treatment; becomes actionable
if injury results.
b) Examples
i) The “no show” patient and the 3 letter approach
ii) Coverage during absences: answering service, reachable, selection of
competent coverage.
5) Medical Informed Consent
a) Definition: A process by which one individual agrees to allow another individual
to intrude upon their bodily integrity or their rights where the agreeing party is
competent to consent and the consent is given voluntarily and with a reasonable
degree of knowledge of the factual situation.
b) Elements of informed consent:
i) Standards
(1) Professional Standard: That amount of information which the reasonable
medical practitioner would provide under the same circumstance
(2) Materiality standard: What the average patient would require to make a
decision under the same circumstances
(3) Combined standard: Reasonable medical practitioner plus whether it was
“sufficient to insure informed consent”
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ii) General requirements:
(1) Nature of condition and procedures to be performed
(2) Nature and probability of material risks involved
(3) Reasonably expected benefits
(4) Inability to predict results
(5) Irreversibility of procedure if that is the case
(6) Likely result of no treatment and available alternatives including risks and
benefits of each.
iii) Voluntariness
(1) Free of coercion, subtle or overt
iv) Competency
(1) Task specific
(2) Legal concept(competence) vs. clinical practice (capacity)
6) Confidentiality
a) Definition:
i) Professional’s duty to keep matters revealed in confidence from third parties
b) Circle of knowing model:
i) Inside: patient, co-treaters, staff, consultants, supervisors, facility accepting in
transfer
ii) Outside: lawyers, outside therapists and or physicians, previous physicians,
family, police
iii) Exceptions:
(1) Emergency
(2) Waiver
(3) Incompetence
(4) Commitment
(5) Statutory requirement, e.g. child abuse
(6) Statutory exceptions; malpractice allegations, collections, litigation in
which mental status is raised as an issue
(7) Duty to Warn or Protect Third Parties (Tarasoff)
7) Privilege
a) Definition:
i) Patient’s right to have matters revealed to a professional held in confidence
ii) Testimonial Privilege: right of patient to prevent therapist from testifying in
an administrative or judicial proceeding about information revealed during the
course of therapy.
b) Belongs to and can only be waived by the patient
c) Exceptions: same as for confidentiality
d) Now exists in all federal courts: Jaffee v. Redmond 116SCt 1923 (1996)
i) Established the privilege in all Federal courts
ii) Extends it to social workers
iii) Takes notice that there is both an important private interest in effective
psychotherapy as well as a public interest of “transcendent importance”
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REFERENCES
American Psychiatric Association. 1987. Diagnostic and Statistical Manual of Mental
Disorders., 3d ed., Rev. Washington, D.C.: American Psychiatric Press.
Freud, Sigmund. 1959. Further recommendations in the technique of psychoanalysis. In
Collected Papers, vol.2, E. Jones and J. Riviere, eds. New York: Basic Books
Kaplan, Harold, and Alfred Freeman. 1989. Comprehensive Textbook of Psychiatry, 5th
ed. Baltimore: Williams and Wilkins.
The Principles of Medical Ethics with Annotations Applicable to Psychiatry. 1989.
Washington, D.C.: American Psychiatric Association.
Phillips, Robert T.M. 1996. The Psychiatrist as Evaluator: Conflicts and Conscience.
New York Law School Law Review. Vol. XLI, No.1.
Schouten, Ronald. 1998. Lectures in Forensic Psychiatry. Massachusetts General
Hospital/ Harvard Medical School Board Review Course. Boston, Massachusetts.
Simon, Robert. 1990. Legal liabilities of an “impossible”profession. In American
Psychiatric Press Review of Clinical Psychiatry and the Law, vol. 2, Robert I. Simon,.ed.
Washington, D.C: American Psychiatric Press.
Simon, Robert and Robert Sadoff. 1992. Psychiatric Malpractice: Cases and comments
for Clinicians. Washington, D.C.: American Psychiatric Press.
Simon, Robert. 1994. Treatment Boundaries in Psychiatric Practice. In Principles and
Practice of Forensic Psychiatry, Richard Rosner, ed. New York, Chapman and Hall.
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