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TORONTO -- Cult members who kill can be grandiose and delusional, controlling and violent. They can claim to communicate with God. They can claim to be God. But are they insane?

From a medical point of view, the answer obviously varies from case to case (and some would argue that insanity is not a medical concept). But from a legal point of view the answer is "no," according to a psychiatric resident at the University of California Davis Health System.

In general, courts and juries are not impressed with a plea of not guilty by reason of insanity (NGRI), Holoyda said in an a presentation at the American Psychiatric Association annual meeting.

In a review of several dramatic cases of cult behavior that ended in murder, Holoyda said, the bottom line was that an NGRI plea based on cult membership alone is bound to fail.

The courts have held that joining a cult is voluntary, so that any act that follows from that choice is also a matter of free will and -- if it's criminal -- will be punished in the normal way, he explained.

Psychiatrists called in to evaluate such cases need to be aware that just being in a cult isn't by itself evidence of legal insanity; evidence of other mental illness would be required to support an NGRI plea, he told 番茄社区app.

"Typically, cult members adhere to beliefs that most people outside of the organization would regard as unusual or bizarre," he said.

For that reason, it's hard for outsiders to judge whether the beliefs of individual cultists are grounded in the teachings of the cult or are delusional.

Psychiatrists seeking guidance in such cases will not find much in the standard texts. Holoyda noting that the DSM-IV-TR and the DSM-5 don't actually mention the issue.

The earlier manual had a diagnosis called "shared delusional disorder," but made no specific mention of cults or religious beliefs.

The category was removed for the DSM-5, but there remains something called delusional disorder, which again is "no clear help in determining whether or not cult beliefs are considered psychotic."

"As many forensic researchers do when the DSM provides limited help, I turned to the law," Holoyda said.

As far back as 1944, the U.S. Supreme Court ruled that freedom of religion includes the right to adhere to views that are "rank heresy to followers of orthodox faiths."

But lower courts have still had to face the issue many times since. To investigate, Holoyda searched the LexisNexis database for cult-related murder cases that reached the appellate level.

Of the 398 cases he found, there were seven unique cases of cult-related murder.

Perhaps the most famous are the , in which followers of charismatic convict/musician Charles Manson killed several people.

Oddly, Holoyda said, no one charged in the slayings ever entered an NGRI plea.

But had they done so, many other cases suggest, the courts would have wanted more than membership in the cult to accept it. Aside from murders and cults, the cases he presented share an important feature -- every NGRI plea failed, Holoyda noted.

The pattern even held true in a , in which a cult leader and his son were charged with murdering other cult members. The father, Michael Ryan, was sentenced to death although the defense argued he was a paranoid schizophrenic.

Son Dennis -- just 15 at the time of the killings -- was also convicted, despite diagnoses of dependent personality disorder, shared paranoia, and shared psychotic disorder.

The analysis makes perfect sense, commented Svetlana Milenkovic, MD, a Toronto psychiatrist who was not part of the study but who moderated the APA session at which it was presented.

'I completely agree with the point of view of the courts," Milenkovic told 番茄社区app.

Killer cultists begin by taking control of other people, using drugs, violence and emotional and physical violence, she said, but that doesn't mean that people don't know right from wrong or that they can't control their behavior.

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