DIRECT EXAMINATION OF ROBERT HICKS BY VAL PRICE
I have worked as a law enforcement specialist with the State of Virginia and in the Department of Criminal Justice Services which is the state agency which oversees training and hiring standards for law enforcement officers. (BETR 3013) I've been with that agency a little over 8 years now. My primary work is to help local law enforcement administrators manage their departments better, both sheriffs and police departments. I help them on a broad range of management problems, to develop good sound written policy. Before that I have had a variety of jobs both in and closely aligned with law enforcement. I've been a police officer with the Tucson, Arizona Police Department. Also an administrator with the Pima County, Arizona Sheriff's Department. I was also a U. S. Navy cryptological officer. I have done some private consulting as well. (BETR 3014) I have published in certain fields of law enforcement concerning the connection between anthropology and law enforcement programs. Most recently dealing with the topic of so–called occult or satanic crime and involvement with law enforcement in that topic. I have written a book on that and several articles with a piece of another book as well. I have a chapter in the book called, "The Satanism Scare" edited by 3 sociologists, Joel Best, Jim Richardson and David Romney. It is slated for the academic book market which is part of a series of sociological studies.

There are probably a dozen other articles that I published on whether or not satanic crimes actually exist or do not exist. They are short articles for various bulletins and newsletters, the titles of which I can't remember at the moment. There were two articles for a publication called The Skeptical Inquirer. Another publication for the American Library Association Journal. There are also some public talks transcribed and circulated. (BETR 3015)

I have also published in the area of astronomy. The name of my book is In Pursuit of Satan: The Police and the Occult. I formulated policies and procedures of police departments. One of the areas that I cover is learning about different types of trends in law enforcement. Part of my responsibilities at the Department of Criminal Justice Services to keep abreast of professional trends in law enforcement. My book was an outgrowth of that, keeping up with some of those trends. In 1986, we began noticing rising numbers of professional seminars for and by law enforcement officers on this broad topic of satanic crime, occult crime, cult related crime. (BETR 3016) It went by several different names. As part of my process to monitor and help interpret new professional trends, I began to attend some of the seminars, particularly those that were for law enforcement to gather what was going on, how significant a problem it was. As I began to attend the seminars, I began to form a suspicion that some of the information presented was not accurate enough for police practice. I thought some was unconstitutional and some was downright illegal.

So as I began to research this, I formed the idea of doing some writing to present some skeptical viewpoints about this and so I therefore wrote the articles, and that eventually led to the book which is a study of law enforcement response to this phenomenon. The phenomenon is in response to existence or non-existence of occult type crimes. Specifically, the fear that had developed and was communicated through law enforcement seminars that a belief in satanism was on the increase, however that was defined. And that a belief in čatanism or certain occult subjects was indicative of criminal behavior as well and that people found to be practicing these other religious behaviors might also be engaged in crime. That was the central ideology of these occult seminars and as a result of that belief, various checklists were circulated, presented as lists of indicators of what one might look for to uncover this kind of crime. (BETR 3017) My book challenged the premise that there is any rising criminal problem with this. It also challenges the idea that it enforcement requires any particular resources or new investigative strategies to get at this.

MR. PRICE: Your Honor, at this time I'd like to submit Mr. Hicks as an expert in the field of police policies and procedures particularly as dealing with the trend of whether or not cult related crimes actually occur. (BETR 3018)

(BETR 3019-3031 is omitted as irrelevant to Mr. Baldwin’s appeal)

I have done research in this area and used empirical data to do this research. The beginning of the research was attending the actual seminars given to police audiences by police officers who claim to have enough investigative expertise to know more than everybody else in the room. That is how a lot of police training actually operates. These, are courses that are offered for in–service credit in Virginia so officers can retain their certification. In attending these seminars a number of claims were made including that this satanic problem in the country involved 4 levels of activity all of which impinge on criminality in some way. At one end the seminars posited dabblers as teenagers, young adults listen to a lot of heavy metal music, sport emblems, symbols from that or from quote/unquote occult literature. At the other end, officers are saying you have satanists that are underground in society. Visibly they're responsible people like everyone in this courtroom but by night they practice satanic rituals, which involve murder, kidnapping or mutilation. (BETR 3032) I wanted to chase down the criminal aspects of this because my primary interest is what is in this for law enforcement, what should be a matter of law enforcement policy, what should be a matter of law enforcement training. The more seminars I attended, the more investigators I talked to, I began findings that the most alarming claims made did not come from field experience but rather secondhand information. I set out to try to track down this information, the claims made, to the source if I could. The outcome of that was not only the book but many conversations both with investigators, academics, even legislators, since this came to the interest of our state general assembly. It came to talking to people who even proclaimed to be involved with satanic worship, quite a few people. The upshot of the research was that the most alarming claims appeared to have no validity in fact. We have no evidence at all to support the idea that there's this underground cult that kills upwards of 50,000 people a year, which is a figure by the way that Griffis has claimed in his own teaching, which I have heard directly. He and other cult cops, as they are popularly called both in and out of the profession, have maintained that as well as maintaining on the other end of the scale listening to certain kinds of music, dressing in certain ways, wearing certain kinds of jewelry, is one step closer to being enslaved by a satanic cult which is going to make you commit crime, very violent crime. (BETR 3033) In doing the research on my book, I studied the methods, materials, and writings of Griffis. I started with Griffis' talks both in public and for law enforcement. I obtained information about his doctorate dissertation. (BETR 3034) Griffis gave, the opinion that this crime had the trappings of a satanic crime and that as it goes to whether or not that was a particular motivation. There are certain factors that Griffis used to base his opinion on. (BETR 3036) I am familiar with certain types of lists which some cult cops use to analyze whether or not a crime fits into a quote satanic crime. These are checklists that are circulated at the training sessions, offered for the officers to take away, stash away, until they think they see any of these elements. Then they pull out the lists and try to compile a picture. The elements on these lists are things to look for to alert the officer that he might be dealing with either a satanic group or some other identified group - satanist, occult groups. These characteristics include a wide variety of phenomena. You look to see if a crime occurred on a specific date that may correspond with a pagan holiday to there may be alphabet signs and symbols which the officer is encouraged to look for. The lists would number into the thousands of characteristics. There has been testimony that the satanic cult awareness pamphlet was one that was used by the investigators in this particular case. (BETR 3037)

(BETR 3038-3040 is omitted as irrelevant to Mr. Baldwin’s appeal)

In regards to the first figure about the dates as being significant of occultism, there's testimony that May 1 was Beltane and April 30 was Walpersnaucht. Those dates frequently show up on these checklists we've been talking about as indicators of a possible cult in the neighborhood, to look for activity that cult cops occurs in those times. There is not any empirical data on whether or not a particular crime that's been committed has been a cult related crime based on these particular dates. I can only think of one study which only examines the common assumption that lots of crime happens at the full moon. Griffis testified, according to his calendar, there were 13 satanic dates of which he focuses in on to determine whether or not a crime occurs on those dates. I am familiar with a kind of calendar list such as that. (BETR 3042) Griffis testified if it fell within a week of a particular satanic date, then that was a factor to be considered. There's a new system out called Instant Based Reporting of Crime Around the Country tThich gives us a lot of information we didn't have before. I, on the few inquiries I've made about this nationally, see no influence of these dates on the prevalence or absence of violent crime one way or the other in Virginia. Another factor that Griffis discussed was the manner in which the victims were tied "in a display fashion." I looked at some of the crime scene photographs which showed the manner in which the 3 victims were tied. (BETR 3043)

There is not empirical data concerning the manner in which the victim is tied if that relates to whether it is a satanic or occult type crime. There's no data that finding a body bound in that fashion is any clue to a religious ideology that I know of. In the field of law enforcement, there are other explanations as to why a body could be tied in that manner besides a cult related killing. Law enforcement, agencies everywhere have found adults bound in strange fashions and found dead. Some of those are termed autoerotic deaths, that is, you bring on some strangulation to help simulate nearness of death to get some' sort of sexual satisfaction. Since this case involves children, obviously I would not offer that up as an explanation. I have investigated when I was a police officer sex crimes that involved tying of victims and killing them. Another factor used by Griffis in making his opinion was the type of injury, particularly the removal of the testicles and the manner in which the penis of Byers was carved upon, the skin being removed and the head being removed but the shaft still being there. (BETR 3044) Griffis used the word crytos.

I have never seen any empirical data or studies to support the idea that a body was mutilated in that manner incident to a religious ritual or a cult related crime. Griffis testified about the torture and the beatings that the victims received. As far as any empirical data or studies that show that the particular manner in which the children were beaten was as the result of an occult crime. I only know of one example where heads were beaten incident to a religious ritual which occurred 3,000 years ago. (BETR 3045) Griffis testified about a Rhode Island case that he testified he was involved in but he didn't remember the date or location in which a pentagram was actually found at the crime scene, and the body was tortured and later burned. I am not aware of the Rhode Island case. I have heard of an incident in California 10 years ago.

I have a small problem with part of your question when you say "cult crime." (BETR 3046) Part of the reason I wrote my book is because of the loose terminology. A crime is a crime and to put the word cult in front of it simply adds a big cloud of smoke and the term loses precision.

Another factor he testified to was the absence of blood relating to the presence of water. I'm not aware about any empirical data or studies, if that is a factor that is used in an opinion whether or not a crime has the trappings of occultism.

Well, I will answer the question, but again trappings of occultism to me is a meaningless phrase. I'm not aware of a body of water playing a significant role in any religiously motivated serious crime. I have studied different types of satanist, Wiccan, and other religious beliefs. In my book I discuss the different religions before discussing the cult phenomenon itself. (BETR 3047) Water probably figures significantly in Wiccan beliefs. I'm probably not the person to be a spokesman for that religious viewpoint. Since Wicca is a religion that claims an origin that precedes Christianity and involves goddesses, spirits that infuse living things, obviously water is a living thing to them and is a powerful symbol but a very favorable, benign one at least. I have looked at State's Ex. 28, the photograph. Hypothetically, if there was testimony from the law enforcement officers that appeared on the scene that that portion on the side of the bank there appeared to be cleaned up and looked like it had scuff marks, that there was no leaves, and Ridge and Allen testified that that was a clean area; and another factor that Griffis referred to was that that was a cleaned up area. Whether I am aware of any specific empirical data that a clean crime scene has any kind of indications of an occult type crime (BETR 3048), it is claimed by Griffis and other seminars that when the underground satanic cult conduct their rituals and murders, they dispose of the bodies and they clean up all traces of the ritual. We have no examples of any of these things. The claim goes so far as to say the fact that they clean it up so well is evidence of their success. So if you find a crime scene with nothing there, that could also mean satanists certainly used the spot.

There are other opinions in law enforcement that a crime scene that looks the way that one does, described by the other officers. There are other explanations in law enforcement of what a cleaned up crime scene could mean besides it is a satanic crime. (BETR 3049) I assume that this is the crime scene and do I assume it has been cleaned up before casting my opinion of other things it could that be. I would say that's like most crime scenes I investigated as a police officer where somebody tried to hide the evidence or hide evidence that they had been there and done the deed. (BETR 3050)

By looking at that same picture for the hypothetical, if I assume that the bodies were found in the water but nothing was cleaned up, that could mean any number of possibilities. If the crime scene had not been cleaned up and bodies were in the water, there still might not be any more evidence than I see in this picture. I'm aware of no empirical data to tie victims injuries on one side of the face or the other to any religious ritual.

State's Ex. #123 there has been testimony that that document was an item that Echols wrote that item at least 2 years prior to the murders which occurred May, 1993. There is nothing of particular religious significance by looking at that document. (BETR 3051) It appears to be a notebook, some random thoughts, quotations. I have seen other similar notebooks. In addition, in the back there's some lyrics to a heavy metal Metallica song. Cult cops look at heavy metal rock groups making their opinion that a particular crime could be a satanic or cult crime. In fact cult cops, have recommended at seminars to other officers that they find ways to go into rooms in homes where the teenagers live, find out what music they listen to, see what books they're reading, and see if they are keeping notebooks like this.

I have seen State's Ex. #112, a photograph from a skating magazine. State's Ex. #110 (BETR 3052) which was State's Ex. #113 and 114 were posters in Echols' room and State's Ex. #116 which looks like an animal skull. This is much debated and there are many people who will attest that this type of material will lead to darker thoughts and actions. There's no empirical evidence to suggest that where the Metallica music is concerned, we have empirical evidence to suggest that the music does not cause the kind of harm that is imputed to it, or that it will lead people to commit crimes. The item on top of the book appears to have spells or potions or something of that nature. If the testimony was that those writings were written a year prior to the murders, there are no significant studies I am aware of that if anyone writes or has a book that contains that type of material that is any type of motivation for a particular crime. (BETR 3053) I am aware of no empirical study that links either as a causative factor or any other way, this sort of writing with the commission of crime. In my studies I am aware of the writings of Ken Lanning with the FBI and what his opinion on the subject is. (BETR 3054)

(BETR 3055-3056 is omitted as irrelevant to Mr. Baldwin’s appeal)

The material the defense sent me contained a 2-page questionnaire of Griffis and then the answers. He sent that to Ridge and then Ridge responded to that and sent the answers back to Griffis which he used to base his opinion on. (BETR 3057)

(BETR 3058 is omitted as irrelevant to Mr. Baldwin’s appeal)

When Griffis testified in his opinion that this particular crime which occurred in West Memphis on May 5, 1993, had the trappings of occultism. In my opinion to apply that phrase, "has the trappings of the occult," is absolutely meaningless in considering any kind of violent crime. An issue I have had with these police training seminars has been that usually in a very nebulous way those who are disposed to thinking along these cult lines will say, such and such a crime was linked to the occult or had trappings of the occult or was related to the occult. (BETR 3059) I've found that it's a meaningless statement because for investigative purposes it means nothing, and has no bearing on anything. The term "occult" has no fixed meaning anyway. In most people's minds it usually refers to certain kinds of practice, certain symbols and signs, that we don't observe and practice, but other people do, people who do nasty things, is usually the way that connotes in the popular mind. To say the word "trappings" again is simply to imbue the whole crime with the tint of something evil. For some police officers that almost gets into a Christian moral fight. Some officers who teach Griffis' point of view teach that you have to be spiritually armed when you investigate these offenses which in my view gets outside of what law enforcement is here to do. So I object to that kind of statement and in the teaching that I have done on the subject, I emphasize keeping that kind of language out of the investigation. In all of those cases I was asked to testify for the defense on a matter of standard police practice or policy. I help agencies develop good, sound written policies. I have created a manual on law enforcement policies and procedures which is widely used not only in Virginia but elsewhere. (BETR 3060)

Occasionally law enforcement agencies are sued and a question arises on a matter of policy, whether an officer, say, made a wrongful arrest, wrongful imprisonment or maybe even wrongfully killed somebody. That is the allegation pursuant to acting according to a written or unwritten department policy, and it's usually the defense that's quick to ask my help to come in to testify about what law enforcement policy is, how it should be created, how it should be used as a standard for training and discipline. In those instances I was asked to testify against the police departments because the allegation was the police departments either had no written policy or had a policy which may have been out of date, illegal or even unconstitutional.

CROSS EXAMINATION OF ROBERT HICKS BY BRENT DAVIS
In the past I was there to speak against the, law enforcement agencies. I was subpoenaed through the defense to testify. I am not saying it my opinion is that a crime is a crime and whether religious beliefs were involved or influenced that crime is really of no significance. (BETR 3061) I am saying that police have tried and true methods of criminal investigation, and they ought to adhere to them. If through the investigation they find that somebody committed a crime incident to a religious ritual, obviously they shouldn't ignore it, and it could play a part in the investigation. My concern is that the belief system or looking at it from strictly an occult or satanic point of view might narrow the focus of the police officer's investigation too much. Those terms have been bandied about in the cult seminars we discussed earlier. I think it is given undue focus to generalized fears rather than specific investigative elements. If those elements were elements of a certain religious belief that became apparent through an investigation, it would be the officer's duty to investigate that aspect of the crime. I mentioned to the State while we talked before court about a case involving Richard Rarnirez, the guy they call the "Night Stalker." (BETR 3062) He had stalked, sexually assaulted and murdered quite a few women and was tried and has been in prison for that.

Although I do not agree with the words "trappings of satanic activity," he had' some insignia or some identification with certain satanic symbols. He would enter the courtroom with a pentagram drawn on his hand, and he would show it to the 'jury and say, "Hail Satan," when he walked in the courtroom. It is not my opinion precisely that case would not have the trappings of a satanic murder in the cases in which he was involved. As far as I'm concerned, the man was investigated on suspicion of abducting, sexually assaulting and murdering women, and he was tried and convicted of those. The investigation was in my mind a fairly textbook investigation on how we do those things. The fact that books were found, pictures, other bits and pieces that either came from the very publit Church of Satan, in my opinion this made no difference to the investigation. You have a fairly wide encompassing investigation but what made that case was not looking at satanism, it was looking at other kinds of evidence. (BETR 3063) As I understand from the investigators who testified; they did not tag him a satanist as such, but Ramirez told them he professed to certain beliefs which did involve Satan and satanic power. I considered the belief system of Ramirez, that individually played a relatively insignificant role in that investigation. Therefore, I would not call that a crime with trappings of satanic or the occult. I just call it a crime. As I understand Ramirez, the professed religious beliefs of the person were not significant in the commission of those crimes.

Determining what is the motive of a crime is something a law enforcement officer should look into. When you have a very unusual crime, one that falls outside the ordinary everyday type of criminal activity, you would oftentimes look for a motive that might be unusual. Normal crimes do not have normal motives. (BETR 3064) Abnormal, unusual, bizarre crimes such as this, sometimes have bizarre motives. If evidence uncovered by law enforcement officers indicated that possible motives related to a set of religious beliefs, then that would be their duty to investigate that. In my research and teachings in this area I have looked into some of the authors on some of the occult or satanic writings. I am familiar with Anton LaVey. Anton LaVey founded the Church of Satan in San Francisco in 1966. Alister Crowley was English and lived at the turn of the century. (BETR 3065)

I have read some of Crowley's philosophies and writings. I have mixed feelings that some of his philosophies center around human sacrifice as a method of worship or a method of his religious beliefs. Crowley did not specifically sanction or otherwise condone human sacrifice. I am familiar with Crowley's work Magic in Theory and Practice. (BETR 3067) The last time I opened Crowley was 4 years ago so I can't recall. I have read a good number of the texts you have. Portions of this writing refer to the power of blood as the source of life and refers to bloody sacrifices. Part of it refers to that the greatest sacrifice is a male child of innocence. The high intelligence is the most satisfactory and suitable victim. If a person that followed ideas such as that, it could be a motivating factor in causing them to commit crime. If somebody had read some of the statements, focusing on those and not the broader context, someone could read that as condoning human sacrifice. (BETR 3068) It is possible that could contribute to their activity or actions in the commission of a crime.

I have not gone over the investigation in this case in a piece-by-piece fashion. In fact the very limited documents and photos referred to are the only documents I am familiar with. I looked at the books up here on the stand. I do not know what statements have been taken from witnesses in this case other than those I saw. I do not know what the police did in regard to their investigation. I do not know who they interviewed, how many people they interviewed or what was said in those interviews. (BETR 3069) I am not giving an opinion as to the motivation for this crime. What I have said is that I disagree with those who give opinions that crimes are motivated based on religious belief systems. I think the issue has to be handled very carefully with precise language. I'm certainly not maintaining that such crimes cannot and never have happened. I do not know if it could or did happen in this circumstance.

REDIRECT EXAMINATION OF ROBERT HICKS BY VAL PRICE
I am familiar with the writings of Kenneth Lanning of the FBI. (BETR 3070) I agree with the quote from Kenneth Lanning which is contained in the last page of my book which is, "Bizarre crime and evil can occur without organized satanic activity." (BETR 3071) The law enforcement perspective requires that we distinguish between what we know and what we are not sure of."

RECROSS EXAMINATION OF ROBERT HICKS BY BRENT DAVIS
Bizarre and evil activity can occur with it or without it. (BETR 3072)