Priest arrested for jogging in the nude.

[fredm74]

I didn't see this article posted here. I am just appalled by his harsh punishment if he is convicted. Truly a shame. He was alone in the middle of the night. How is this considered a sex offense?



http://www.sfgate.com/cgi-bin/article.cgi?file=/n/a/200...D79.DTL&type=bondage (http://www.sfgate.com/cgi-bin/article.cgi?file=/n/a/2007/08/08/national/a135924D79.DTL&type=bondage)

[nimrod]

I agree, simple non-sexual nudity should not be considered a sex offence. He was trying to be descreet by jogging when he thought that no one would see him nude, but I believe that he should be able to do that at any time of the day.

[RalphVa]

I looked at the state laws on the NAC webstie for Colorado. They say nothing about being listed as a sex offender if convicted. He's getting wrong advice, or the reporter is reporting incorrect information.

He really shouldn't have said what he did is wrong. What's wrong about it?

[Bobx23456]

I guess he's been defrocked.

Blessings
Bob

[Eric6420]

I think that the american culture tends to demonize sex and nudity.

Look at the video from the young french lady called Alizée. The video is a few years old, but you could see someting like that on alomost any channel, anytime in France. This is mainstream pop music in France.

I do not think that a man would be arrested for wearing a speedo in a fast food in France like it is the case in Arkansas.

Alizée (http://www.youtube.com/watch?v=BHgZRBrWZ8c&mode=related&search=)

[Ken Palmer]

Hey Fredm74. I agree with you on the part that he should not have to register as a sex offender. A sex offender is one who maliciously sets out to either molest or flatout violates someone in a sexual manner. Two examples of that would be a child molester and a rapist. The priest has committed no such act to our knowledge. All he did was allegedly got caught jogging at a high school track in the nude. I just read this article a few minutes when I was logging on. It kind of caught me by surprise. I was kind of shocked that he would do that with the risk of being caught. And I guess I can say that the fact that he is a priest also had me a bit astonished. I can sort of understand the indecent exposure charge. But having him register as a sex offender is going a bit overboard.As a matter of fact, quite a bit! Does anyone here agree with me on this aspect?

Ken Palmer



Originally posted by fredm74:
I didn't see this article posted here. I am just appalled by his harsh punishment if he is convicted. Truly a shame. He was alone in the middle of the night. How is this considered a sex offense?



http://www.sfgate.com/cgi-bin/article.cgi?file=/n/a/200...D79.DTL&type=bondage (http://www.sfgate.com/cgi-bin/article.cgi?file=/n/a/2007/08/08/national/a135924D79.DTL&type=bondage)

[usuallylurk]

Originally posted by fredm74:
I didn't see this article posted here. I am just appalled by his harsh punishment if he is convicted. Truly a shame. He was alone in the middle of the night. How is this considered a sex offense?



Running naked on the grounds of a school? Not too bright.

And it wasn't the middle of the night, it was just before sunrise.

If nudists/naturists are going to retain whatever nude rights they have, they have to use a large degree of discretion.

In the most nude-free state - Vermont - one guy opted to 'push the envelope' by walking down the main street in Brattleboro. He had traveled all the way from Arizona to do that. And he triggered off a backlash, in which other communities in Vermont are now aiming to put anti-nudity reguulations in place.

What would a good lawyer tell a guy who was caught jogging nude on school property?

(assuming he has no prior record of this or other actions)

Do what we call, here in Massachusetts, "coppin' a plea".

First thing the lawyer would do is tell his client to go get his head examined. Then he is armed with a 'clinical defense' when he gets to trial, or pre-trial negotiations with the prosecution. "Oh, my client -- the pressures of his work, drove him over the edge, he did this", adding that his client hurt no one.

The client shows remorse -- either in the form of "I'm really sorry and I'm never gonna do THAT again" or "S**t your honor, I don't know what in creation I was thinking" or, best, both.

Then the lawyer should offer to plead to disorderly conduct, also a misdemenaor, but without the sex offender shroud.

One thing he has going against him - he's a priest. A prosecutor might be licking his/her chops over the attention, notoriety, and folk heroism that a sex offender conviction against a priset would bring.

[bendigonudey]

I think the "priest" angle has certainly had a lot to do with how much publicity this case has received - even made it to National Radio news broadcasts out here in Oz.

I am sure if it was just "Fred Smith, slightly eccentric local nudist" it wouldn't be in the news - the police ight have even told him to put his pants back on and get the hell out of there!

[nudeM]

I agree on two points. One, the issue is being 'exploded' because he is a Catholic Priest and was caught jogging in the nude. The formula (priest + nudity = trouble) seems to be the focus point for the media. Now add to the formula (priest + nudity in public = trouble), now you 'almost' have a full conviction even before the priest sees the judge. Now add to the formula (priest + nudity in public + school grounds = "sex offender" All it took was for the priest to be spotted nude on school property. Along with the other news of the Catholics and their troubles involving kids, this story will be huge.

To be registered as a sex offender is stretching it, but that is what the prosecutors will try for as a result from past cases and convictions. I don't agree with it, but that's what probably will happen.

My second point is jogging on school property, nude no less. Should have used a little more common sense. I wonder if he knew what the consequences would have been if he were caught. Now he is about to find out.

I have gone jogging on our local high school track, and the shorts I wore were very light nylon without the liner. I was as next to nude as possible, but at least I was presentable in public. He should have used a little more discretion, in my opinion. http://oakhurstonline.com/icon/smoking.gif

[Nu]

Originally posted by Bobx23456:
I guess he's been defrocked.
Blessings
Bob

LOL.
Good line.


But yes, the poor fellow is in trouble.
Agreeably, he would have been better to have done this in a desolute country setting rather than a school track.

[FLDave]

Here's a link to another site with more details about what happened.

http://www.thedenverchannel.com/news/13848179/detail.html

[tinner666]

It sounds kinda weird at first, being on school grounds. But, after mulling it over for the weekend, ASSUMING he lives near the school, it would seem logical?? to be there in the dark, as opposed to running around the neighborhood streets and alleys.

[missouriboy]

If convicted of indecent exposure, a misdemeanor, he would have to register as a sex offender... This is the part that galls my craw. Since the trend in law is to now define mere nudity as sexual, countermeasures for the more common-sense truth are obviously called for. But where is there any public venue for the protest of this nonsense?

Warning to all nudists: never "cop a plea" agreeing to "indecent exposure" until you learn the exact local definition of that phrase!

[Kohana_Kioni]

This is where a reporter has a duty to report the facts, instead of labeling the priest as a S.O. and in most states if not all that I am aware of I.E. is not a sex related crime.

You will have to check Colorado's Penal Code for clearity on the matter as Sex Crimes are usually defined as Felony Crime not Misdemeanor Crimes.

[Pete Knight]

When did a journalist ever let the truth get in the way of a good story?

Pete Knight

[Rabid_Clam]

Being nude in public is one offense of the land. Being nude on school grounds is but another. Yet at the time of day he was there the young people were not. There for there could be no sex, only the nudity offense.

That was very, extremely poor judgement on part of the clergy to do this at all and he now will pay the price. But let the price be equal to the crime and lets be sure the crime is only elevated to what it truly is. It is not a sex crime by any means. It is a crime of very poor judgement.

[simonsebs]

Jury will decide priest’s guilt (http://www.timescall.com/news_story.asp?ID=5275)

Here's an update to the story.

[Stu2630]

I think this should have been dealt with by a firm warning from the police that his behaviour is unacceptable and if it ever happens again, he'll find himself in court. Case closed.

I don't believe he should have to appear on the Sex Offenders' Register.

Stu

[Pete Knight]

I think this should have been dealt with by a firm warning from the police that his behaviour is unacceptable and if it ever happens again, he'll find himself in court. Case closed.

I don't believe he should have to appear on the Sex Offenders' Register.

Stu
Yes, but this is America where nudity should only be used for monetary gain, if nudity were widely acceptable Hollywood wouldn't be able to use it for titillation and as selling tool for its products, any half baked story with unknown actors becomes a big seller with a bit of nudity.

Pete Knight

[bishop5508]

Here is an update on this story from local news. Too bad for this priest he was running nude! He would have been much better off if he had been assaulting someone or drunk driving with his clothes on, probably would have never made the news and got off with a warning. As far as the officer being “alarmed over seeing genital”, I wonder if he showers, works out, pees????

http://www.9news.com/news/article.aspx?storyid=83033


This story was further down the home page, must not be as important (even posted after the priest story)
http://www.9news.com/news/article.aspx?storyid=83035
This man gets 5 years for KILLING someone!!!!! Out in 3 to 5???
As Will Mummy said:“It's a hell of a thing, killin' a man. Take away all he's got, and all he's ever gonna have”

[Jason Lee]

I agree on two points. One, the issue is being 'exploded' because he is a Catholic Priest and was caught jogging in the nude. The formula (priest + nudity = trouble) seems to be the focus point for the media. Now add to the formula (priest + nudity in public = trouble), now you 'almost' have a full conviction even before the priest sees the judge. Now add to the formula (priest + nudity in public + school grounds = "sex offender" All it took was for the priest to be spotted nude on school property. Along with the other news of the Catholics and their troubles involving kids, this story will be huge.

To be registered as a sex offender is stretching it, but that is what the prosecutors will try for as a result from past cases and convictions. I don't agree with it, but that's what probably will happen.

My second point is jogging on school property, nude no less. Should have used a little more common sense. I wonder if he knew what the consequences would have been if he were caught. Now he is about to find out.

I have gone jogging on our local high school track, and the shorts I wore were very light nylon without the liner. I was as next to nude as possible, but at least I was presentable in public. He should have used a little more discretion, in my opinion. http://oakhurstonline.com/icon/smoking.gif

I'm not sure discretion is an option

Rev Robert Whipkey is a heavy man wearing clothes + jogging/running he sweats profusely

[usuallylurk]

I don't know why we're even discussing this.

The guy is not a naturist. They guy allegedly ran naked in a public park, on school property, in the wee hours of the morning.

If he did as alleged -- we should not embrace the guy's cause. We should, not walk , but RUN in the other direction.

This is not a naturist rights case. Naturists do not have the right to run through a public park or school grounds at any time of the day or night.

[Pete Knight]

I don't know why we're even discussing this.

The guy is not a naturist. They guy allegedly ran naked in a public park, on school property, in the wee hours of the morning.

If he did as alleged -- we should not embrace the guy's cause. We should, not walk , but RUN in the other direction.

This is not a naturist rights case. Naturists do not have the right to run through a public park or school grounds at any time of the day or night.

That's why its being discussed on a naturist forum, because we are being denied our rights, one day it will be seen as normal to take a walk or jog (un)dressed in any way you want, the 'children might see' issue is a non issue, they won't be offended if they grow up knowing that this is a normal way of life, the social conditioning that bare flesh is wrong must change in America which comes second only to Muslim countries in how such matters are dealt with.

I still haven't got over the fuss made in the nipplegate case, it really amazes me that innocent nudity is cracked down whilst the US porn industry churns out indecent movies by the truck load, where is the common sense in that?

Pete Knight

[Stu2630]

That's why its being discussed on a naturist forum, because we are being denied our rights,

I don't believe you have any right to behave in public in a way which is generally considered offensive or inappropriate. Naturists do have the right to have a fair share of public spaces, but NOT to be naked in front of people who find it offensive.


one day it will be seen as normal to take a walk or jog (un)dressed in any way you want,

I doubt that. And certainly not in our lifetimes.


the 'children might see' issue is a non issue, they won't be offended if they grow up knowing that this is a normal way of life, the social conditioning that bare flesh is wrong must change in America which comes second only to Muslim countries in how such matters are dealt with.

The reason parents don't want their children to see nudity isn't just because it may offend them, it's because they don't want their children to be exposed to the sight of adult nakedness. We who feel that way think that by allowing children to be exposed to such sights firstly encourages them to take an interest in the physiological differences between the sexes - and therefore to be curious about sex, and secondly because it could teach them that it is acceptable to be naked in public when we believe it is revolting and gross.


I still haven't got over the fuss made in the nipplegate case, it really amazes me that innocent nudity is cracked down whilst the US porn industry churns out indecent movies by the truck load, where is the common sense in that?

This was a man violently exposing the bare breast of a woman in a show which they know would be watched by young people. It was wrong and the makers admitted a lapse of judgment.

Stu

[Pete Knight]

Stu

Get a life mate.

Pete Knight

Oh, and a Merry clothed Christmas to you and yours.

[MJ_KC]

Stu

Get a life mate.

Pete Knight

Oh, and a Merry clothed Christmas to you and yours.
Don't hold your breath waiting for this to happen. Stu finds what we want to be offensive, but what he fails to understand is that I find his prudishness to be offensive and I do not like to see people who hide under massive amounts of clothing in order to keep their skin hidden from view.

That does not mean that I am going to insist that the prudes stay out of my view any more that they should be allowed to insist that I put on more clothing than I like to wear. They can avert their eyes if they see something they object to, just as I would have to. I will not change my way of doing things just because the prudes have personal issues.

[nudeM]

I'm not sure discretion is an option

Rev Robert Whipkey is a heavy man wearing clothes + jogging/running he sweats profusely

If this guy is a heavy man, then the question that comes to mind is, why then, did he decide to take up jogging, nude no less? There seems to be more and more questions that pop up the more I read the story.

I still say, he should have used a little more discretion and not used the school grounds. Granted, there were no kids at the time, but still, it was on school grounds just the same. A jury will use that against him i.e. a pedophile who likes to hang around schools (sic).

Hopefully he will get off on just a warning or a simple citation.

[Stu2630]

Pete

I've got a life, thanks - and it's a great life in which social and familial nudity doesn't play any part. That's how I like it! :D

Merry Christmas to you and your family!:fun:

MJ_KC


Stu finds what we want to be offensive, but what he fails to understand is that I find his prudishness to be offensive and I do not like to see people who hide under massive amounts of clothing in order to keep their skin hidden from view.

I don't think you really find it offensive to see people wearing clothes. I bet you wear clothes most of the time yourself. But if you do genuinely find it to be actually offensive, then maybe you need to relocate to a nudist colony away from all us textiles. I'm a big fan of segregation.


That does not mean that I am going to insist that the prudes stay out of my view any more that they should be allowed to insist that I put on more clothing than I like to wear. They can avert their eyes if they see something they object to, just as I would have to. I will not change my way of doing things just because the prudes have personal issues.

The reality is that virtually no-one on the planet is offended by the sight of clothed people, but millions, and possibly billions, are offended by nudity. So we expect our legislators to make rules in that respect in consideration of our sensibilities. As for people "averting their eyes", the same could be said of nudists getting upset by Harold and his friends having an orgy on a nudist beach.

Stu

[Jason Lee]

if he went on a diet and loose weight

solve his problem sweating profusely

[Bob S.]

lurk:"This is not a naturist rights case. Naturists do not have the right to run through a public park or school grounds at any time of the day or night."

One way it is a naturist rights case is that he could be placed on the sex offender registry if convicted even though he did nothing sexual.

Stu:"We who feel that way think that by allowing children to be exposed to such sights firstly encourages them to take an interest in the physiological differences between the sexes - and therefore to be curious about sex, and secondly because it could teach them that it is acceptable to be naked in public when we believe it is revolting and gross."

Children already have a physiological interest in the differences between the sexes. It starts around age three. Their curiosity about sex will always be age-appropriate unless someone actually abuses them. Simply seeing a naked adult will not increase their sexual curiosity, it will simply show them what an adult body looks like. It is the same when they "play doctor" and see what each other looks like naked. That is simply a stage that some kids go through in their sexual curiosity.

Seeing a person naked in public will not teach them that it is acceptable. That is something that the parents do. They talk with their children about what is right and wrong according to their values and the law. If the law accepts it, then they have to go by their own values to explain why it is right or wrong.

Stu:"I don't think you really find it offensive to see people wearing clothes."

Reread what MC said. He mentioned that he finds it offensive when people wear a lot of clothes for the reason of "{keeping} their skin hidden from view." In other words (as I read it) wearing more than enough clothes due to excessive modesty is offensive to MC.

Bob S.

[naked4me]

yes but the question on everyones lips is .

once he was arrested, does that mean he is collared ????
get it ? priests wear collars hahahahahahaha ah doesnt matter

[simonsebs]

Priest caught jogging naked found guilty of indecent exposure (http://cw2.trb.com/news/kwgn-naked-priest-trial,0,5132580.story)

Here's an update to the story.

[Stu2630]

He was rightly convicted of an offence: people can't just take to the streets naked with impunity.

I think the sexual element of the conviction, i.e. him having to be entered on the register of sex offenders, is excessive and unnecessary. He doesn't appear to pose a threat to people sexually. It would have been sufficient for him to have been convicted of a minor public order offence and fined a couple of thousand dollars and put on probation.

Stu

[nuovonudo]

stu, i agree with you; registering the guy as a sex offender is out of order. from the write up it is clear that there was nothing sexual about what he did.

[usuallylurk]

While having this guy put on the sex offender list is a topic of discussion - I'll throw in my .02.

Yes, he was convicted of only one offense -- the indecent exposure.

HOWEVER ... there was an alleged incident in 1999 at a boys' camp, involving him being nude in front of boys. There were also some supportable allegations of his not drawing the shades, and also being in the nude in the neighborhood on other occasions.

While the jury probably shouldn't hear those things when they're deciding innocence or guilt --- the JUDGE certainly can and should use those situations in deciding if he should be put on the sex offenders' list. Is he a sexual danger ... will he attack someone? Probably not. But being an exhibitionist is definitely a sexual offense under the law, and a pattern was laid out.

This conviction AND some credible allegations of past behavior probably led to his listing.

And if you really want to run around nude outside, there ARE places to do that.

[Home Nudist]

I agree, the man broke the law. But, the term "indecent exposure" has bothered me for years. What is "indecent" about the naked body, when one is just walking, running, sitting, or going out to dispose of the trash, just as one would do these things when clothed?

(The question is rhetorical, but I'm sure Stu will explain it to me. Hi Stu ! :dance:)

[Stu2630]

Home Nudist


But, the term "indecent exposure" has bothered me for years. What is "indecent" about the naked body, when one is just walking, running, sitting, or going out to dispose of the trash, just as one would do these things when clothed?

In English law, it wouldn't be classed as "indecent" unless it was either sexual, or intended to cause harassment, alarm or distress (sec. 66 of the Sexual Offences Act 2003), and so law enforcement would look to charging for a public order offence rather than a sexual offence. In some states, however, the term "indecent" has a much broader meaning and it would suffice simply to be naked where it is inappropriate is "indecent" by that very fact.

Stu

[Agde]

In English law, it wouldn't be classed as "indecent" unless it was either sexual, or intended to cause harassment, alarm or distress (sec. 66 of the Sexual Offences Act 2003)...
Priests be warned -- America has strayed quite far from its English common law roots! In the States, "indecentexposure" apparently is usually treated as a single word. Separated, "indecent exposure" suggests there must also be "decent exposure" or at least just plain old "exposure" with some defined subset that is "indecent." Treating "indecent exposure" as one word makes it difficult to prescribe proportionate legal remedies, like the English "public order" type. We are left with prosecutors winning the all or nothing argument, as with the priest, that "it was wrong to be naked, no matter what the reason".

Anyway, the word "indecent" is of course in essence normatively and culturally subjective, so legally problematic in culturally diverse populations. Laws would probably be better served by something more objective like "genital exposure" with legal remedies based on objective criteria like time (4am?), location (high school track?), proximity (who was around except the police?) and sexual intent. Although "intent" is always problematic in law, "sexual intent" combined with "genital exposure" is usually objectively recognizable enough to further inform and fine-tune a judgment. In fact, the general trend internationally for "serious legal consequences" seems to be toward equating "indecent" with sexual intent . Stateside law considerably lags behind in this, but NAC seems to bring it up when it can.

It is old hat as an argument here, but the only way to disentangle nudity from indecency is systematically to challenge laws on indecency that do not focus primarily on sexual behavior. In the priest's case, the defense attorney seems to have made the "nothing sexual" argument, but apparently the law didn't make the distinction. Other sexual allegations were then used as supporting evidence rather than being prosecuted directly.

"Public order" offences, including Stu's favourite "alarm and distress", of course suffer many of the same legal fuzziness and misuse as indecency, but at least they are usually at a misdemeanor level and don't get you on some national blacklist, like the American "sex offenders" list. On the other hand, these days, being registered as a priest may be nearly as bad.

[usuallylurk]

"Other sexual allegations were then used as supporting evidence rather than being prosecuted directly."

They were NOT supporting evidence in the trial. Or they shouldn't be.

However, post-conviction, they were likely a factor in the judge determining if he would be classified as a sex offender.

Exposing one's genitals in a public place in the United States is not a "right"; it is a crime, and considered to be a sex offense.

[Stu2630]

Agde


Although "intent" is always problematic in law...

Virtually all criminal offences in English law require proof of intent - it's what we refer to in the Latin term mens rea, the guilty mind, as opposed to the other element of an offence, the actus reus, or guilty act. Intent is established through a combination of behaviour, circumstances, offender's antecedents and what the offender says before the offence is committed, at the time it is committed or afterwards. When considering intent it is essential to look at the law very carefully to establish "intent to do what?" Sometimes, the intent is very specific, such as with the crime of blackmail where it is "gain for himself or another" or "to cause loss to another", but other times it is enough simply to establish an intent to behave as the person behaved, such as in dangerous driving. Indecent exposure is fairly specific in that the offender must both intend to expose his genitals, and intend that someone will see them and be caused alarm or distress. Minor public order offences also mention alarm and distress, but it is sufficient to show that the offender intentionally behaved in a way that was likely to cause harassment, alarm or distress.


"Public order" offences, including Stu's favourite "alarm and distress", of course suffer many of the same legal fuzziness and misuse as indecency,

That's because what causes, or is likely to cause, harassment, alarm or distress is a question of fact rather than a question of law. That means that the law does not stipulate what these circumstances are, but rather leaves it up to the particular court on the particular day to judge case on its particular facts. This is important because guilt or innocence is (usually) determined not by legally qualified people, but by lay people on a magistrates bench or as members of a lay jury. So it's a matter of common sense applied by ordinary people rather than by members of the legal establishment referring to law books.

Here endeth the (free) law lesson. ;)

Stu

[Agde]

Virtually all criminal offences in English law require proof of intent - it's what we refer to in the Latin term mens rea, the guilty mind, as opposed to the other element of an offence, the actus reus, or guilty act.

Mens rea is a good example of the gap between English and American law, both in the extent to which it is necessarily coupled with actus reus,and the extent to which real or potential victims may seek legal remedy. The problematic nature of "intent" is that it essentially always involves guessing what is going on in someone else's mind. If indecency requires intent, card-carrying naturists should always be able to claim lack of intent to offend.


That's because what causes, or is likely to cause, harassment, alarm or distress is a question of fact rather than a question of law. That means that the law does not stipulate what these circumstances are, but rather leaves it up to the particular court on the particular day to judge case on its particular facts.

Here the problem is in the relationship of "intent", "fact" and "law" since the lay jury is being asked by the law to assess what is going on in at least a couple other people's minds. Since the "fact" is not completely in the "act", the "victim" may claim "feeling alarm and distress" and the plaintif may claim "no intent to alarm or distress" with equally veracity. That leaves the lay jury struggling with an even deeper psychological probe into what each side "should have known" was going on in the other's mind. Inevitably, it comes down to some idea of social norms and tolerances in given circumstances -- which is exactly what a lay jury has every right to expect the law to be clear about in the first place. That's why "indecency" must ultimately be linked something more "factual" like sexual behavior.

[Stu2630]

Agde


If indecency requires intent, card-carrying naturists should always be able to claim lack of intent to offend.

True. And this applies to indecent exposure. But be a bit careful here because many offences in English law include recklessness as an option for intent. A card-carrying naturist who walked naked down a street could be guilty of a public order offence notwithstanding the lack of intent to cause harassment etc if the court were satisfied he knew, or ought to have known, that his actions could have those effects.


Inevitably, it comes down to some idea of social norms and tolerances in given circumstances -- which is exactly what a lay jury has every right to expect the law to be clear about in the first place.

That's not the approach our legal system takes. People (jurors, lay magistrates) are expected to come to the court with their own life experiences, so they would be able to empathise with a victim and also rationalise what the defendant would have known, or ought to have known, about their victim. They would be expected to be equipped with some insight into "social norms and tolerances" and to apply them in their deliberations.


That's why "indecent exposure" must ultimately be linked something more "factual" like sexual behavior.

I agree. I always said that ordinary nudism should not be "indecent exposure" or any other sexual offence. If done in an inappropriate place, it should be treated as a potential, minor public order offence on the same level as using obscene language or urinating. In those cases, the main priority of law enforcement is to cause the immediate cessation of the behaviour and thereafter to apply an appropriate legal response ranging from a warning (in the case of, for example, innocent intent followed by immediate compliance with a request to dress) up to arrest for a public order offence (in the case of, for example, persistent nudity and non cooperation with a request to dress etc).

Stu