Paranoid clients: Whose reality is real?

Paranoia is a difficult topic to address in the client context. It is, as you likely know, a disorder in which a person is very suspicious and distrustful of others. MedlinePlus, an informational website provided as a service of the National Library of Medicine and the National Institute of Health, describes the symptoms in this way:

People with paranoid personality disorder are highly suspicious of other people. They are usually unable to acknowledge their own negative feelings towards other people.

Other common symptoms include:


  • Concern that other people have hidden motives
  • Expectation that they will be exploited by others
  • Inability to work together with others
  • Poor self image
  • Social isolation
  • Detachment
  • Hostility[1]


There is also a type of lesser distrustful behavior that lacks the more psychotic persecutory elements of delusional paranoia. This type is called “functional paranoia” because it serves the function of reducing the sense of vulnerability that often accompanies the loss of independence and control experienced by the elderly. In essence, functional paranoia is a coping mechanism. However, the “distrust, suspiciousness, and blaming of others can take on an angry quality that certainly can be aggravating for others.”[2]

A paranoid client is problematic for legal professionals in at least two respects, (1) they mistrust just about everyone, including the legal professionals who are attempting to help them, and (2) it is difficult to separate out the reality from the unreality of the information they provide. To a great extent the empowered paralegal will already be prepared for dealing with the first of these problems, because the paralegal will already be communicating fully with clients. When the client’s paranoia is functional, full communication can empower the client and diminish their feelings of vulnerability. However, even though functional paranoia fulfills a rational purpose, the paranoia ideation itself is not rational; the definition of paranoia is irrational suspicion. You cannot expect someone for whom paranoia is a coping mechanism to suddenly stop the ideation simply because you are in fact very trustworthy and have only the client’s best interests in mind.

Paranoia is subject to treatment. Counseling in which “an individual focuses on changing negative, self-defeating beliefs or misconceptions, may be useful in treating paranoid older adults who often attribute causality to external factors (e.g., the belief that someone took their pocketbook, that they themselves did not misplace it)”[3]may enable that individual to redirect those beliefs. However, we as legal professionals cannot make it our role to counsel or treat paranoia. Rather, we best perform our role when we understand the paranoid client and use that understanding to better work with the client.

Here are some suggestions for coping with the paranoid client:

  • Do not take his mistrust personally
  • Keep the client fully informed on a consistent, regular basis
  • Speak and write in short, simple, and clear sentences to minimize misunderstanding and misinterpretation
  • While you must check fairly constantly the client’s thoughts and statements against reality, do not constantly confront the client with that reality. Remember, the clients delusions are reality for them. Chose these “battles” wisely.
  • At the same time that you let client statements and ideation pass without openly questioning it, do not indicate that your are accepting or “buying into” the client’s paranoia. Be firm and respectful in protecting and projecting your own reality. (We are, of course, all hopeful that our reality is the reality, but be mindful that each of our realities is, at least, colored by our own biases, prejudices, and suspicions.) Do not see monsters under the bed just to keep the client happy.
  • Be open to the client’s discussion of her mistrust and suspicions. Let her know that she is free to voice them to you. Clarify misunderstandings about your actions or motivations in a non-defensive, non-judgment way.
  • Anticipate events that are likely to give rise to mistrust and suspicions. Explain proceedings and the role of the persons in them well in advance. For example, it is useful for any client to know that a mediator may be meeting with both sides of a dispute privately and that such meetings may not be equal in length, but this is essential information for a paranoid client.
  • Focus on the client as a whole and as an individual. Do not focus on his symptoms.

The empowered paralegal is also well-equipped to separate out legal relevant portions of client reports from the legally irrelevant, and is likely to have considerable practice at separating fact from fiction in the client’s rendition of her side of a case. Our client’s reports to us are always colored by their particular perspective, biases, prejudices, desires, and motivations. Paranoid clients are an extreme form of this. However, they are more than just an extreme form of this phenomenon. Non-paranoid clients, unless they are simply lying, color reality, but do not irrationally misjudge it.

This is a problem for the legal professional because we must make our judgments and recommendations based on the facts. If our clients are showing signs of paranoia, we need to be ever more mindful of our obligation to verify the facts before taking action. Michael Nugent Moore, a paralegal and licensed private investigator located in Boston, commented on this topic in a NFPA LinkedIn discussion thread. He gives this example,

While working as an investigative paralegal, I had a client who was a WW II vet. He believed that someone had stolen stock from him. His mind seemed sharp, but he had bouts of paranoia. I found numerous facts that contradicted his report of the situation and I was informed that paranoia is the initial manifestation of dementia. It was a real strain constantly trying sort out reality.

However, we must also avoid swinging too far in the other direction. There is tendency to discount or even ignore everything a paranoid client says, especially when they are making accusations against people who appear to us to be above such accusations. The sad fact is that all too often an elderly client’s own children, and the nursing home personnel entrusted with the care of the elderly, do steal from, neglect, and abuse those for whom they are providing care. We cannot assume these problems are not occurring simply because the client displays signs of, or even has been diagnosed with, paranoia.

Finally, as is the case with depression discussed previously and dementia discussed in the next section, paranoia provides cause for concern regarding our client’s competency.

 [Excerpted and modified from The Empowered Paralegal: Working with the Elder Client.]


[1] Medline Plus, (Last accessed March 17, 2010)

[2] Sheldon S. Tobin, Preservation of  the Self in the Oldest Years, Springer Publishing Company (1999), 14.

[3] Hooyman and Kiyak, 235

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