Despite being tried and acquitted for raping two teenage girls, actor Errol Flynn fortified a lasting reputation as a womanizer and modern-day Romeo. Many argue that the expression “in like Flynn,” a phrase suggestive of assured sexual success, stems from the sensationalism of Flynn’s rape trial in 1942.
Film actor Errol Flynn had attended a party on September 27, 1942, at a Bel Air residence owned by silent-screen actor Colleen Moore and jointly leased by three others: Freddy McEvoy, a former Olympic bobsled champion, and actors Bruce Cabot and Stephen Raphael. Also attending the party was seventeen-year-old Betty Hansen. On the morning of October 11, two police officers—Lieutenant R. W. Bowling and Sergeant Edward Walker—arrived at Flynn’s home to question him on reports that he had had sexual intercourse with a minor child (which was a felony).
Errol Flynn, left, with his attorney, Robert Ford, at Flynn’s 1942-1943 trial in Los Angeles for rape.
Police officers then went to juvenile hall to interview three young Warner Bros. employees: eighteen-year-old Armand Knapp, twenty-two-year-old Morrie Black, and twenty-year-old Joseph Geraldi. All had been arrested for attacking Hansen after Flynn’s alleged assault.
Hansen told police that Flynn had forced himself on her for intercourse, adding that she had protested his actions but ultimately did not resist. The case against Flynn, for statutory rape, first went before the Los Angeles grand jury on October 15 but was thrown out following a ruling that there was no criminal case.
Continuing private investigations by members of the district attorney’s office, however, eventually revealed an earlier complaint against Flynn for sexual intercourse with a minor. The name of Flynn’s accuser in this earlier complaint was Peggy Satterlee. Satterlee’s mother had lodged a complaint with the Los Angeles County Sheriff’s Department almost fourteen months earlier after an episode that occurred between her daughter and Flynn on Flynn’s yacht, Sirocco, on the weekend of August 2-3, 1941. Satterlee’s mother claimed that the actor had seduced her then-fifteen-year-old daughter. Police had investigated the accusations at the time but decided there was no case against Flynn; police also convinced the Satterlees not to pursue the case.
Even with the grand jury’s ruling in Hansen’s case in October, 1942, however, the newly elected district attorney, John F. Dockweiler, determined to pursue the actor. Dockweiler combined the two complaints (from Satterlee and Hansen) and filed his case on November 20.
Both Hansen and Satterlee testified for the prosecution. They were represented by Assistant District Attorney Thomas W. Cochran at a preliminary hearing before a grand jury. Cochran established the grounds of Hansen’s complaint: Flynn had escorted her into one of the upstairs bedrooms of the Bel Air mansion on St. Pierre Road, removed her clothing, disrobed (except for his shoes), and had sexual intercourse with her on one of the beds. The grounds of Satterlee’s complaint was that Flynn had twice forced himself upon her while she was a guest aboard his yacht in early August, 1941.
Flynn’s arraignment before Judge Edward R. Brand took place on November 23. Flynn pleaded not guilty to three counts of rape. His trial date was set for January 11, 1943, and he secured his release after posting bail, which had been set at one thousand dollars. The trial, heard by Superior Court judge Leslie E. Still, would last twenty-one days. Flynn’s defense lawyer, Jerry Giesler, who was retained by Warner Bros., shrewdly ensured that the jury comprised three men and nine women.
During trial, Giesler easily discredited the testimony of both Hansen and Satterlee. He was able to admit as evidence Hansen’s previous sexual history, which essentially undermined the public role she was adopting as a chaste and innocent young woman. Black and Geraldi both testified to having had sexual intercourse with Hansen. Giesler also relentlessly challenged specific points of Hansen’s testimony, including her claim that Flynn had locked the door of the bedroom in which the alleged rape had taken place. During his pretrial investigations, Giesler had had the door removed from the Bel Air mansion, introduced it into evidence, and substantiated that the lock had in fact been broken at the time of the incident, thus showing that it was not possible for Flynn to have locked the door, as Hansen had alleged.
Satterlee’s allegations against Flynn were more serious: She claimed that Flynn raped her twice and that she had fought back each time. As in the case with Hansen, however, Giesler relentlessly challenged specific points of Satterlee’s testimony. Giesler exploited Satterlee’s job as a nightclub dancer and established that she often exaggerated her age to secure work. Her driver license had indicated that she was twenty-one years old.
Damaging the prosecution’s case was Satterlee’s testimony that she had seen the moon through a porthole of a cabin aboard Sirocco when Flynn raped her. Giesler demonstrated that the moon could be seen that night only on the other side of the Sirocco; thus, he established that it was not possible for Satterlee to have seen the moon as she had testified. This point cast considerable doubt on her credibility.
More damning to the prosecution, and more sensational and scandalous, had been Satterlee’s sexual history, admissible in this case under California law. Giesler had received an anonymous tip to investigate a figure from Satterlee’s past: a former friend named Owen Cathcart-Jones. Cathcart-Jones, a Canadian pilot, was then forty-two years old. Giesler later admitted to manipulating Cochran into calling Cathcart-Jones as a character witness for Satterlee. This gave Giesler the opportunity to cross-examine Cathcart-Jones about an incident involving Satterlee at a Los Angeles funeral parlor. Cathcart-Jones testified that Satterlee had “frolicked” among a number of cadavers, removed sheets from bodies, peered at them, and on one occasion pushed her head down against the face of a deceased elderly man’s body.
Perhaps the final blow to the prosecution’s case, however, was when Satterlee confessed during cross-examination to having had an abortion before she had met Flynn. Abortion in the state of California was a felony at the time. Satterlee’s declaration of guilt in this matter raised suspicion that she was testifying against Flynn to avoid her own possible prosecution for the abortion.
The jury returned its verdict after a twenty-four-hour deliberation. On February 6, 1943, jurors found Flynn not guilty on all three counts of rape.
Flynn’s autobiography, My Wicked, Wicked Ways, was published the year he died. Many claim that Flynn originally wanted to call the book In Like Me, a play on the expression “in like Flynn,” but that his publisher, G. P. Putnam’s Sons, refused to do so.
Earl Conrad, in his biography Errol Flynn: A Memoir, claims that the phrase “in like Flynn” materialized because of Flynn’s trial. Similarly, Thomas McNulty, in Errol Flynn: The Life and Career, implies that the phrase came to exemplify a man’s sexual skill in seducing a woman during the time that Flynn stood trial for rape—beginning around early January, 1943.
Incidentally, some sources claim Dockweiler, the Los Angeles district attorney, had had an ax to grind against Warner Bros. studio. Peter Stackpole, who had been on Flynn’s yacht on the weekend of August 2-3 (the same weekend Satterlee was on the yacht), claimed that while two candidates were running for district attorney at the time, Warner Bros. backed one man for the job, and it was not Dockweiler. Others, such as Lionel Godfrey in The Life and Crimes of Errol Flynn, claim that Flynn believed Dockweiler to be morally vengeful toward Hollywood and that this resentment motivated Dockweiler to make an example of him.
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Conrad, Earl. Errol Flynn: A Memoir. New York: Dodd, Mead, 1978. This biographical account of Flynn’s life was written by the coauthor of Flynn’s autobiography. -
Flynn, Errol, with Earl Conrad. 1959. New ed. My Wicked, Wicked Ways. London: Aurum, 2005. Flynn and cowriter Conrad present a revealing autobiography. -
Godfrey, Lionel. The Life and Crimes of Errol Flynn. London: Robert Hale, 1977. Godfrey’s account of the rape trial includes the claim that Flynn believed Dockweiler to resent Hollywood and that this resentment motivated Dockweiler to attack Flynn’s integrity. -
McNulty, Thomas. Errol Flynn: The Life and Career. Jefferson, N.C.: McFarland, 2004. McNulty’s documentary analysis of Flynn’s life and career includes photographs, some rare and some previously unpublished.
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