In Re the Detention of Jeffrey Goodwin, Dr. Dennis Doren, a psychologist, was accepted as an expert witness in a jury trial, the judgment of which was later appealed to the Supreme Court of Iowa. Doren testified of sadism, and his words were repeated in the Court's judgment, "that the person is sexually aroused by the infliction of pain or humiliation to individuals".
In Diaz, Justice Fagg of the United States Court of Appeals wrote:
"We have defined the term sadism as the infliction of pain on a love object to obtain sexual release, and as delight in physical or mental cruelty."
Writing in the Alberta Law Review, Wayne Renke commented on R v Neve in which a rarity occured: a woman, Lisa Neve was given dangerous offender status in Canada, which hilighted the typical context of the relevance of sadism as it presents in law (sex):
"The American Psychiatric Association's Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition, or DSM - IV, sets out two main criteria for sexual sadism. Criterion A requires evidence, covering a period of at least six months, of recurrent, intense sexually arousing fantasies, sexual urges, or behaviours involving acts (real, not simulated) in which the psychological or physical suffering (including humiliation) of the victim is sexually exciting to the person.
"Criterion B requires evidence that the fantasies, sexual urges or behaviours cause clinically significant distress or impairment in social, occupational, or other important areas of functioning.
"The diagnosis of sadism was supported by the evidence of the robbery (interpreted as an act of sexual humiliation), and of another incident in which Neve, on the pretext that a "date" had made a special bondage request, deceived a prostitute into joining her in a hotel room, where Neve bound the prostitute, naked, with duct tape, and threatened to assault her, apparently with a knife. Dr. O'Mahoney testified that for a person to be found naked is a huge humiliation for that person to suffer and to do this to a person is the manifestation of an extreme attempt at humiliation. Neve's fantasies took on significance as Criterion A indicators of sadism."
- Duhaime, Lloyd, Duhaime's Legal Dictionary
- Duhaime, Lloyd, Duhaime's Legal Citations & Abbreviations
- In re Detention of Goodwin, 689 NW 2d 461 (2004), at Footnote #2.
- Renke, Wayne, Case Comment: Lisa Neve, Dangerous Offender, 33 Alta. L. Rev. 650 (1994-1995)
- U.S. v Diaz, 368 F. 3d 991 (2004)
- US v. Wolk, 337 F. 3d 997 (2003)