Avoid conclusionary language. Rather, describe thoroughly.
Officers frequently use the term "paranoid" to describe an individual who is under the influence of certain drugs, particularly cocaine and methamphetamine. Well, unless you have performed a psychiatric assessment of the person resulting in a diagnosis of paranoid schizophrenia, avoid using the term "paranoid" in your report, as well as on the witness stand. Paranoia is a very specific mental disorder, characterized by delusions of persecution.
Rather, thoroughly describe what is was about the individual's appearance and behavior that lead you to conclude that the person was paranoid. For example, the individual may be fidgeting, moving his/her head back and forth to see if anyone is behind them. The person may express feelings of irrational fear. The person may have a "case of the windows," and may express the thought that imaginary people are watching him/her. The reader of the report, including the judge and jury, may conclude from the descriptions of the person's behavior that "Wow, it sounds like he was paranoid."
"Following too close" is another frequent example of conclusionary language. Explain why and how you determined the person was "following too close." After all, you want others to agree with your conclusion.
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