DECLARATION OF DR. ALAN L. BERMAN
FILED WITH THE FRANKLIN COUNTY SUPERIOR COURT
(As part of our lawsuit against
the Pasco School District, it had to be proven, or argued, that Jared became
depressed as a result of bullying and an assault by another student at
McLoughlin Middle School. Dr. Berman was retained and paid to give
his professional opinion to support our case. Bold print and underlining
is emphasized by my, Brenda High's initiative. Below is his report.)
Alan L. Berman hereby declares, under penalty of perjury,
"My professional practice and study has focused on the
subject of suicide for at least 25 years. Throughout that time, I
have been particularly interested in the causes and prevention of adolescent
suicide, including suicides of young people in Jared High's age range.
I have testified in trials and depositions throughout the United States,
in both state and federal courts, as an expert in suicide. A frequent
task for me in such cases is to form an expert opinion on the causal relationship
between a given event and an individual's suicide, and I have testified
as an expert on that subject on numerous occasions. A substantial
portion of my time is and has for years been working clinically with suicidal
patients, including young people and adolescents.
"...I have received and have reviewed at least the following
1. Family video clips, ...audio recording
of the interview he (Jared) gave to the school district's claim investigator...
2. State of Washington Uniform Incident Report
concerning the assault on Jared High, May 6, 1998.
3. Notebook of Pasco Public School District's
Answers to... Interrogatories...
school records and a transcript
of the above recorded interview.
4. Notebooks of Plaintiffs' Answers ...interrogatories
...records ...material from McLoughlin...
5. Deposition... chiropractor... medical
6. Deposition ...vice principals ...teachers.
7. Deposition ...vice principal who disciplined
both Jared High and his assailant, A.S. (A.S. = The Bully)
8. Deposition of A.S.
9. Records of C.H., who counseled A.S. at
various times, starting in 1991.
10. Excerpts of A.S. ...medical records, ...showing
that he was 65 inches and weighed 177 pounds, at 14 years of age.
11. Deposition of ...Jared's older brother.
12. Deposition of Jared's mother...
13. Deposition of Jared's father...
14. The police report of Jared High's death...
15. Transcript of ...former expert witness
16. Written statements by Jared's older sister,
... and his grandmother...
17. The HMS student weekly progress report ...less
than two weeks before his death.
18. A note (on an) arithmetic test sheet addressed
to Jared's counselor at HMS... from the HMS math teacher...
"I have interviewed Jared High's parents, older sister,
...adult leader of Jared's Boy Scout Troop... ...Jared's schoolmates...
...medical doctor, father of a girl Jared was rumored to have some sort
of relationship with at HMS briefly before his death....
"...The following are my professional opinions, within
a reasonable degree of psychological certainty, based upon my training,
education, experience and study of the psychology of suicide and my investigations
in this case:
"Jared High did not exhibit the symptoms of clinical
depression prior to the May 6, 1998 incident with Andrew S. at McLoughlin
Middle School and its subsequent disciplinary aftermath. In the
weeks and months following, however, Jared High developed the symptoms
of a major depressive episode. By the nature of the diagnosis, a
major depressive episode develops over time. By September, 1998,
Jared High had a diagnosable condition of clinical depression. In
my opinion, the May 6, 1998 physical altercation at the hands of Andrew
S. and the subsequent discipline of Jared High by McLoughlin Middle School
Vice Principal L.A. are significant causal factors in the development of
that depression, such that it is unlikely that Jared would have developed
that depression and the impulse to commit suicide if those events had not
"It is my professional opinion that Jared High's state
of mind at the time of his suicide was distorted and irrational, that his
thinking at the time was characterized by feelings of hopelessness and
'tunnel vision' such that he could see no alternatives. Such feelings
and thoughts are a direct result of processes over which Jared High had
no volitional control, based in both the biological and psychological roots
of his depression. Because of these factors, Jared High was unable
to resist the impulse to end his suffering through suicide.
"It is further my opinion that clinical depression
and suicide are a forseeable consequences of a school district's failure
to constrain a known bully from victimizing other students. This
is not just my opinion, but is a view widely held among those who study
suicide, based upon repeated scientific studies. Some of the more
well-known studies are:
Kaltiala-Heino, R., Rimpela, M. et al. (1999). Bullying,
depression, and suicide ideation in Finnish adolescents: School survey.
Medical Journal , 319 (7206), 348-351.
National School Safety Center (1995). School bullying
NSSC Resource Paper (7th Printing). (31 pp).
Batsche, G M. & Knoff, H. M. (1994). Bullies and their
victims: Understanding a pervasive problem in the schools. School Psychology
Review, 23 (2). 165-174.
Harvard Education Letter (1987, November). Bullies
and their victims, 3 (6), 1-3.
"At my deposition, I provided defense counsel with thirty-four
pages of information, including abstracts of journal articles and bibliographies
of other articles, about the relationship between bullying, depression
and suicide. Bullying is a professionally discussed problem and an
issue of professional import for schools around the world, including the
United States. The rates of bullying are remarkably consistent around
the world. Bullies and their victims display significantly more psychiatric
symptoms than other children. Bullying has been shown to cause
victims to become emotionally distressed and, in particular, to develop
clinical depression. Clinical depression is one of the greatest
risk factor for suicide among all age groups, and particularly so for youths
and adolescents. Bullied students are 5 times more likely to develop
depression than students who have not been so victimized, according to
a study in England published in 1998. A 1999 Finnish study
showed bullied students were at increased risk for depression and suicide,
with victims four times more likely than non-victims to become depressed
and twice as likely to develop severe suicidal ideation. These studies
go back at least to 1987."
Dr. Alan L. Berman is a Clinical
Psychologist, practicing in Washington D.C.
HEAR JARED'S VOICE - PLAY
- From an interview with Pasco School District investagators concerning
the assault. This is a recording of a recording and it isn't real
clear, but worth the download effort. Jared had a real mellow voice.
Note: If you have a slow load wav, wait for it to load entirely and then
play again from the start. 5 minutes long