For the study of historical relationships between law and psychiatry, many approaches are possible. A few scholars have focused on particular relationships [22, 19, 23], while most have incorporated legal aspects into more general reviews of the history of psychiatry in the United States¹ [ 11, 13, 8] . Yet to be explored in any depth are the legal implications of moral therapy, legal aspects of the mental hygiene movement as it emerged during the latter part of the 19th century, and legal terms used as metaphors by physicians characterizing concepts of health before 1900.² Another approach would be to examine the thoughts of American physicians who wanted their 19th century colleagues to accept the importance of utilizing their knowledge of insanity in helping courts of law perform their societal tasks. Although more narrow in scope and seemingly more remote from a study of mental health concepts, I believe that this focus of historical inquiry can be illuminating.