[Plaintiff] v. United States of America
U.S. District Court, District of Massachusetts
Experts retained by defense included:
Harold J. Bursztajn, M.D. (forensic psychiatry)
Associate Clinical Professor
Co-founder, Program in Psychiatry and the Law
Department of Psychiatry
Beth Israel Deaconess Medical Center
Harvard Medical School
96 Larchwood Drive
Cambridge, MA 02138
ph. 617-492-8366
e-mail: harold_bursztajn@hms.harvard.edu
Summary:
A plaintiff was struck by a U.S. government-owned vehicle while running
across the street outside a major teaching hospital in a high-traffic
area of Boston. Plaintiff brought a civil action in federal district
court against the U.S. government, claiming that the traumatic brain
injury caused by the accident had left him with ongoing cognitive deficits,
psychiatric symptoms, lost income, family conflicts, reduced enjoyment
of life, and emotional distress.
Among the expert witnesses retained by the U.S. Attorney’s Office of the
District of Massachusetts was forensic neuropsychiatrist Harold J. Bursztajn,
M.D., of Harvard Medical School. He reviewed clinical records indicating
that the plaintiff had suffered a relatively minor brain injury—specifically,
a small right parietal epidural hematoma accompanied by some contusion
in the left frontal lobe—which resolved in a rapid and uncomplicated
manner after some initial expansion of the hemorrhage. An expert in neurosurgery
opined that such an injury was not likely to result in impairment of
memory, language use, or executive functions. Although such an injury
might result in some impairment of affect, attention, or judgment, in
examination Dr. Bursztajn found no significant impairment in these areas.
In examination, plaintiff did not manifest the degree of cognitive impairment
that he claimed (including the need for an English-language interpreter).
On the contrary, his self presentation as impaired had at times a deliberate
quality consistent with impression management. Plaintiff’s performance
in psychological testing was likewise consistent with unreliability in
his self reports. These examination findings were consistent with five
years of clinical records documenting claimed impairments out of proportion
to the expected effects of the brain injury. Clinicians who treated or
evaluated the plaintiff saw indications of somatization (i.e., experiencing
psychological distress in the form of physical symptoms) and of self-dramatization
as a victim.
Dr. Bursztajn found these data to be consistent with Factitious Disorder
(one variation of which has been known as Munchausen syndrome)—that is,
the intentional production, feigning, or exaggeration of symptoms in
order to assume a sick role. He opined that the plaintiff’s claims of
impairment were largely an expression of sick role adaptation to the
dislocations and deprivations (emotional as well as material) he and
his family had suffered since they immigrated to the United States. These
losses, compounded by difficulties in cultural assimilation, undermined
plaintiff’s traditional role as family head and provider. In Dr. Bursztajn’s
opinion, it was likely that the plaintiff was using his alleged accident
related injuries and impairments as a passive and convenient focus of
blame for a preexisting and persisting family crisis that underlay his
vulnerability to symptom exaggeration and misattribution. Thus, the accident
gave the plaintiff a simple medical explanation for a psychosocial catastrophe.
In a bench trial, the judge took all expert testimony (direct examination)
in the form of affidavits submitted before trial. After rigorous questioning
of witnesses in the liability phase, the finder of fact entered judgment
in favor of the defendant on the basis of his finding that the plaintiff,
by the way he ran out into the street from between cars, was entirely
at fault for the accident. Thus, the testimony with respect to causation
and damages did not directly bear upon the verdict. Nonetheless, the
prior submission of this testimony may have provided the court with a
context for evaluating the plaintiff’s reliability as an informant about
the facts of the accident as well as about the damages allegedly resulting
from it.