Compliance: The Uncomfortable Reality of Docile Bodies

by | 14 Jan 2013

“Normal men do not know that everything is possible” – David Rousset1As quoted in Hannah Arendt The Origins of Totalitarianism 1951.

The movie Compliance2Directed by Craig Zobel, Magnolia Pictures (2012). For a trailer and summary of the plot see is disturbing on many different levels, and left me with a feeling of extreme discomfort, and even disorientation, long after the credits rolled, no less because it is based on true events, referred to by the American media as the “strip search prank call scam”. As the story unfolds in the movie in the same sequence as it did in reality, Sandra, the manager of an Ohio “Chickwich” fast-food outlet, receives a call from a man falsely claiming to be a police detective. Referring to himself as “Officer Daniels” or “Sir”, he accuses a young female cashier, Becky, of stealing money from a customer. He then enlists Sandra’s assistance in physically detaining Becky in the store room of the outlet and strip-searching her. Sandra and two other employees are caught up in events that become increasingly unsettling, escalate throughout, and ultimately culminate in the degrading sexual abuse and humiliation of Becky by Sandra’s boyfriend, Van.

Although many viewers in the US reacted to the movie with visceral disgust, the events are barely embellished and are portrayed relatively accurately by Zobel, who also made every effort to ensure that the movie was not just another exploitative voyeuristic representation of women’s bodies. Furthermore, the real and narrativised versions of Compliance can be seen as reflective of two famous psychological experiments: the experiments on obedience to authority figures conducted by Yale University psychologist Stanley Milgram, where participants obeyed instructions to apply electric shock to ‘victims’, even to the point of causing what had been described as extremely painful and physically dangerous to the recipient;3Stanley Milgram Obedience to authority: an experimental view 1974. and the Stanford University prison study conducted by Philip G Zimbardo in 1971 where students were divided into groups comprising of “prisoners” and “guards” with horrific consequences as they played out their respective roles and expectations of their assignments.4Philip G Zimbardo The Lucifer effect: How good people turn evil 2008. See also an interview with Zimbardo on YouTube Put simply, these experiments have been interpreted as showing that ordinary subjects can be easily influenced to apply lethal force to innocent people when acting under pressure to comply with orders issued by those perceived to have the authority to do so. More importantly, conformity and obedience to authority are accepted as virtues by a majority of the subjects. Indeed, in terms of societal norms, conformity and compliance are key ingredients for success – and indeed survival – in the military, prisons, schools, sports teams, and in the workplace. Milgram has been quoted as saying that “… [o]rdinary people simply doing their jobs without any particular hostility can become agents in a terrible destructive process. Relatively few people have the resources needed to resist authority”. This is how Sandra is portrayed in the movie: an ordinary person trying to do what is expected of her, to “do the right thing”.

The cinematic depiction of events – in what can be called a “perfect storm” of compliance –begins with Sandra experiencing a stressful work day, with too many customers and too little bacon as a result of a broken refrigerator. As she tries to resolve the problem and manage the situation as effectively and efficiently as possible, a “police officer” calls, accusing a “young blonde girl” of stealing money from a customer’s purse. Sandra automatically assumes that it is Becky, who vehemently denies it. Although initially uncertain, Sandra becomes overwhelmed by her managerial responsibilities, and complies with the caller’s orders to detain Becky in an effort to do the right thing and to please someone who she believed has authority over the situation despite there being no evidence that he was indeed a police detective. This decision to comply begins a nightmare that tragically blurs the lines between expedience, legality and reason in a way that illustrates Michel Foucault’s disciplinary society:

There are two images, then, of discipline. At one extreme, the discipline-blockade, the enclosed institution, established on the edges of society, turned inwards towards negative functions: arresting evil, breaking communications, suspending time. At the other extreme, with panopticism, is the discipline-mechanism: a functional mechanism that must improve the exercise of power by making it lighter, more rapid, more effective, a design of subtle coercion for a society to come. The movement from one project to the other, from a schema of exceptional discipline to one of a generalized surveillance, rests on a historical transformation: the gradual extension of the mechanisms of discipline throughout the seventeenth and eighteenth centuries, their spread throughout the whole social body, the formation of what might be called in general the disciplinary society.5Michel Foucault Discipline and punish: The Birth of the prison “Panopticism” 1995 (my emphasis).

The caller, who asserts his authority on the phone from the outset, is stern with Sandra — and the other people who are later called upon to guard and search Becky — when a controlling influence is needed, but also passes that authority on to Sandra and Van to exercise when necessary. Sandra, Van and Becky respond to his perceived authority as a law-enforcer in ways that are shaped and constructed by their own respective positions in a social hierarchies; their understanding of legality and the importance of obeying the law; as well as the fear of not conforming and having to face the consequences of non-compliance and ‘belligerence’. This in turn illustrates the way in which Foucauldian disciplines (re)produce bodies and identities in ways that operate as effective mechanisms of social control and the normalisation of power:

… although the police as an institution were certainly organized in the form of a state apparatus, and although this was certainly linked directly to the centre of political sovereignty, the type of power that it exercises, the mechanisms it operates and the elements to which it applies them are specific. It is an apparatus that must be coextensive with the entire social body and not only by the extreme limits that it embraces, but by the minuteness of the details it is concerned with. Police power must bear “over everything”: it is not however the totality of the state nor of the kingdom as visible and invisible body of the monarch; it is the dust of events, actions, behaviour, opinions — “everything that happens”; the police are concerned with “those things of every moment”, those “unimportant things”, of which Catherine II spoke in her Great Instruction (Supplement to the Instruction for the drawing up of a new code, 1769, article 535) (ibid).

In a sequence of what can only be described as unbelievable events over a time period of approximately three and a half hours, Sandra is told to take away Becky’s cell phone and search her purse for the stolen money. She is then ordered to instruct Becky strip and to search her clothing for the money. She calls in another female employee, Marti, to be a witness, but she leaves shortly after the strip search and gets back to work. These demands are all made on the phone, gradually becoming more even more bizarre. In order to manipulate her into complying with his increasingly unreasonable demands, the voyeuristic caller both reprimands and praises Sandra, who is eager to please, and assures her that she is not responsible for what happens to Becky as he claims to assume full responsibility for all actions under his direction as the officer “in charge”. In addition to reprimanding and praising Sandra and the other compliant participants, he uses fear and the need to conform to push the boundaries even further. For instance, he justifies the strip search by claiming that the only alternative would be for Becky to be imprisoned while her home is searched. When Becky is alone, the caller threatens that she will lose her job, be imprisoned and that her brother could also face drug related charges if she does not comply calmly with the strip search. After she has stripped, Becky is covered only by an apron.

In the next surreal twist, Officer Daniels instructs Sandra to put Becky’s clothes, underwear and shoes into a bag and take it to her car for later inspection by the police. He initially claims that clothes can sometimes have hidden pockets, but when Sandra is perplexed by his order, he states that the larger investigation involves possession of marijuana, and that the clothing may contain faint traces of it which would aid the case. In a moment that seems to defy reason, she complies. In Compliance, Sandra, Becky and Van are re-created as docile bodies, subjected and used, playing passive roles in the very system that harms them. Foucault’s conception of “docile bodies” emanates from his seminal work Discipline and Punish,6Supra. in which he argues that individuals are under constant surveillance and regulation (‘panopticism’) in ways that are often subtle and thereby seemingly invisible, leading to the acceptance and normalisation of such systems. Foucault focuses on the body specifically as the sight of regulation, or more specifically “as object and target of power”. The notion of ‘docility’ – the point at which the analysable body and the manipulable body are joined – is employed to illustrate how individuals within their bodies are subjected to institutional regulation, order and discipline.

As these happenings unfold, others are drawn into the web. Another young male employee, Kevin, is recruited to “guard” Becky while Sandra tries to help out with the large numbers of customers. When instructed by the caller to remove Becky’s apron and inspect her naked body he refuses, and states that the situation is “fucked up”. However, despite clearly disagreeing with what is happening in the store-room, he goes back to simply “doing his job” in the front of the store.

As the store is busy, and she is becoming increasingly stressed, Sandra calls her boyfriend (who she refers to as her fiancé) Van to come in and help “guard” Becky upon the instructions of the caller. Van, who is slightly drunk when he arrives at the restaurant, proves easy to manipulate. Soon Officer Daniels has him removing the apron; describing her breasts and vagina to him over the phone; forcing her to jog and do jumping jacks naked; spanking her repeatedly for ten minutes for being ‘disobedient’; conducting a patently illegal “cavity search” for the missing money; and finally compels her to perform oral sex on him. When Sandra comes in at some stages during this orgy of cruelty, Van covers the silent Becky with the apron, but the sexual abuse continues when they are alone. When Van eventually becomes too nervous, Officer Daniels suggests that he leaves.

Sandra then requests the maintenance man, Harold, who is called in to fix the broken refrigerator, to watch Becky until the police arrive. Harold, thankfully, is almost instantly outraged by the caller’s demands and is the first person to disobey his instructions. When he is told by Officer Daniels that strip-searching Becky “isn’t your choice,” he responds “like hell it isn’t”, and refuses to cooperate. After Harold tells Sandra about the caller’s intentions, she phones the regional manager and for the first time in hours realises that the call is a scam. The police arrive at the scene five minutes after being called.

The above events, captured on CCTV footage, took place at a McDonalds fast food restaurant in Mount Washington, Kentucky on 9 April 2004.7For censored CCTV footage of the events and interviews with Ogborn and Summers see In the process of investigating the case it was discovered that 69 similar calls were made to various other fast food outlets, restaurants and grocery stores over a period of 12 years, although the MacDonalds incident went much further than any of the others. An arrest was made in 2004, although the accused was eventually acquitted in 2006 for lack of direct evidence that he was the perpetrator in this case.8The accused, David Stewart, was acquitted by a jury in 2006. See The 18 year old victim, whose real name is Louise Ogborn, instituted action against MacDonalds for not putting in place adequate measured to prevent the incident from happening. The jury in the Bullitt Circuit Court civil trial, concluded in November 2007, 9Action No. 04-CI-00769. awarded the victim $5 million in punitive damages and $1.1 million in compensatory damages and expenses. Donna Summers, her compliant supervisor (assistant manager at the store), was awarded $1 million in punitive damages and $100,000 in compensatory damages as she insisted that she thought she was doing the “right thing” and was found to be ignorant of the fact that Ogborn was being assaulted by her fiancé. The jury decided that McDonald’s and the unnamed caller were equally at fault for the abuse to which the victim was subjected. In 2009 the Community of Kentucky Court of Appeals affirmed the civil court decision except for the punitive damages awarded to Summers, which were reduced to the “constitutionally acceptable” amount of $400,000.10See the appeal judgment at 43 year old Walter Nix (the fiancé referred to as “Van” in the movie) pleaded guilty to sexual abuse and other crimes in February 2006. Because he was the principal perpetrator of the sexual abuse and engaged in a sex act, he received a five-year prison sentence. 11ABC news report: “Man Gets 5 Years for Role in Fast-Food Strip Search Ploy”, 15 March 2006 at Summers entered a plea of guilty to a criminal charge of unlawful imprisonment, and received one year of probation. She was not charged with any sex-related crimes. Footage from the CCTV cameras has been leaked onto the internet, with pornography sites showing clips of the vaginal “inspection” and naked jumping jacks.

Some reviewers in the US have dismissed the claim that the movie is based on true events as “a mere generic and aesthetic strategy that may as well be the modus operandi for horror films over the last decade”, precisely because it is such an unbelievable set of events. Zobel is accused of “questionable representations of class relations that get overlooked in the consideration of its more salacious material”.12See in particular The cinematic portrayal is dismissed as an attempt at sensationalising the abuse of the female body and “attempts at affecting certain emotions in its audience”. The movie is described as “the representation of a grim, uncanny narrative about the influence of bureaucracy and a re-examination of Michel Foucault’s writings in a contemporary context”, with accusations of academic exploration/ exploitation of a disturbing theme crafted for the “art house crowd”: Compliance is described as a cornucopia of academic ideas ensconced in the “gritty realism” of fast food restaurants. Furthermore “[a] nagging smugness permeates the film, making the material into an angst-ridden rant against conformity rather than a potentially politically powerful film that provokes us to reconsider our relationship to the screen as well as systems we belong to”. The latter statement is ironic, in the sense that the aesthetic nature of the narrative is not central to it. The main complaint is that Zobel provides a class-ist portrayal of events and fails dismally at providing an explanation for Sandra motivations for her inaction, as if that is possible at all.

This kind of defensive and ignorant analysis is almost as disturbing as the story itself, illustrating an inability to reflect on and engage with the events, or to open up to the kind of doubt, uncertainty and introspection that does not allow the viewer/ voyeur to distance him or herself from the abuse that plays itself out on the screen. It is far safer to reject the truth of the story, as this does not require viewers to ask difficult questions of themselves and the systems that construct their identities and embody their truths. Admittedly, however, my own attempts at understanding the dynamics can also be seen as no more than a form of academic voyeurism.

There are no easy answers as to why the participants in this prolonged humiliation of an 18 year old cashier acted as they did, or indeed why she submitted to the extent that she did, but it could be seen as an illustration of how knowledge, power and discipline have subjected and subjugated the human body, and especially the female body, to the extent that there is very little room for resistance, a fact that clearly frustrates, and even escapes, many commentators who simply find the movie offensive, and who, perpetuating the very system that they seek to resist, do not see beyond the cinematic imagery, which merely serves as a reflection of the “erotic” cruelty inflicted on real but also artificially constructed bodies.

Narnia Bohler-Muller is Deputy Executive Director, Democracy and Governance, Human Sciences Research Council and Adjunct Professor, Nelson Mandela School of Law, University of Fort Hare, South Africa.

  • 1
    As quoted in Hannah Arendt The Origins of Totalitarianism 1951.
  • 2
    Directed by Craig Zobel, Magnolia Pictures (2012). For a trailer and summary of the plot see
  • 3
    Stanley Milgram Obedience to authority: an experimental view 1974.
  • 4
    Philip G Zimbardo The Lucifer effect: How good people turn evil 2008. See also an interview with Zimbardo on YouTube
  • 5
    Michel Foucault Discipline and punish: The Birth of the prison “Panopticism” 1995 (my emphasis).
  • 6
  • 7
    For censored CCTV footage of the events and interviews with Ogborn and Summers see
  • 8
    The accused, David Stewart, was acquitted by a jury in 2006. See
  • 9
    Action No. 04-CI-00769.
  • 10
    See the appeal judgment at
  • 11
    ABC news report: “Man Gets 5 Years for Role in Fast-Food Strip Search Ploy”, 15 March 2006 at
  • 12
    See in particular



Join 4,679 other subscribers

We respect your privacy.


*fair access = access according to ability to pay
on a sliding scale down to zero.



Publish your article with us and get read by the largest community of critical legal scholars, with over 4500 subscribers.