From the October 5, 1896 Brooklyn Daily Eagle:

“Atlanta, Ga.–If the ruling of Judge Foute of Atlanta obtains, hypnotists will have to be very careful what they order their subjects to do. The judge holds that the hypnotist is directly responsible for the acts of his subjects.

During a performance at a local theater the subject of hypnotism imagined he was a monkey. He grabbed a hat off a man in the audience and bit a piece out of it. The professor and his business manager declined to make good the cost of the hat, and the hypnotist was prosecuted before Judge Foute upon a charge of malicious mischief. The justice sustained the charge and bound the hypnotist over to a higher court.”