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Case 1:20-cr-00330-PAE Document 424-3 Filed 11/08/21 Page 16 of 29 110 J. Engle and W. O'Donobue When parsing these domains, it can be more clearly seen how BPD may serve as a pathway for false allegations of sexual assault. The first domain (Leib et al., 2004) includes the diagnostic criterion of quickly switching from idealization to devaluation of relationship (American Psychiatric Association, 2000). The instability of relationships experienced by an individual with BPD may be rooted in the tendency to quickly switch from idealizing significant others or lovers to devaluing them (American Psychiatric Association, 2000). This sudden change in conceptualization of a partner is often caused by feel- ing that the partner is not caring enough or giving enough or by suspicion of abandonment. The rapid shifting between idealizing and demonization may bring about a change in perspective such that a relationship that was viewed idealistically in the past is now seen through the devalued lens of abuse or mistreatment. Past events then may become construed as “abuse” and may lead a person with BPD to believe he or she is a victim of sexual assault. As Kanin (1994) found in his longitudinal study, two of the three major motivations to file a false allegation of rape were attention-seeking and revenge. The switch from idealization to devaluation of the relationship and/or relationship partner (American Psychiatric Association, 2000) may spur a desire for revenge for any past behaviors that are, in the devalua- tion phase, newly construed as mistreatment. In addition an individual with BPD who is feeling fear of abandonment may seek frantically to achieve the attention that is craved from the partner who is perceived to be neglectful (American Psychiatric Association, 2000). The impulsive nature of a person with BPD may also lead them to act on these motivations for attention or revenge by filing a false allegation of sexual assault before carefully consid- ering the consequences. Also, there is some evidence that individuals with BPD engage in behaviors that are viewed as “manipulative” (Linehan, 1993). Manipulative behaviors are often outside the conscious awareness of the individual and are learned through positive reinforcement, as manipulation frequently results in positive outcomes for the manipulator. Thus, an indi- vidual with BPD may use a sexual assault allegation as a way of impacting a third party for some desired outcome. The second domain (Lieb et al., 2004), consisting of symptoms of reality-based delusions and hallucinations, may lead to false beliefs of sex- ual assault, and clinical experience suggests that sexuality is a common theme in delusions and hallucinations. The DSM-IV-TR (American Psychiatric Association 2000, p. 299) defines delusions as “erroneous beliefs that usu- ally involve misinterpretations of perceptions or experiences.” Hallucinations involve sensory experiences that do not appear to be externally caused. Thus, individuals with BPD may represent a “perfect storm” of symp- toms in which an impulsive, emotionally dysregulated individual who is demonizing someone and has loose contact with reality and who is seeking DOJ-OGR- 00006284