Can’t remember what I was looking for on the Library of Congress’s site, but what I found was this 2014 article by then-intern Anne Guha on the important topic above. I was immediately intrigued, even though the topic is only tangentially relevant to my professional responsiblities, and never mind why that might be.

I was glad to see the Library’s law blogs are (1) still operating in 2026 and also (2) haven’t been limited to administration-friendly topics yet. (I was a little concerned to get 19 results when I searched for “Greenland,” but the posts are all several years old and entirely sane.) In fact, a surprising number of the posts involve topics that could just as easily appear on this site (and very well may). See, e.g., Elin Hofverberg, “What Rules Govern the Grindadráp (Whale Hunt) in the Faroe Islands?” (July 29, 2025).

Wait—the Grindadráp has rules? I guess that explains all these official-looking letters from the Faroe Islands that I haven’t been opening.

The zombie-law article is one of several the Library’s published on or around Halloween. According to Guha, she was watching a documentary about “modern zombie culture”—2014’s “Doc of the Dead“—which claims that zombie creation has been common enough in Haiti that the country’s criminal code specifically prohibits it. She wondered if that was actually true, and decided to look into it with the help of the Library’s expert on Francophone law, the unfortunately named Nicolas Boring.

As is so often the case, the answer is that it’s kind of true. But mostly false.

According to the Library’s research, before 1865 Haiti’s criminal code said this (in French):

Art. 246. Poisoning is defined as any attack on a person’s life through the effect of substances that can cause death more or less promptly, in whatever manner these substances have been used or administered, and whatever the consequences may have been.

That’s pretty broad, but not broad enough to cover zombie-making, in my professional opinion. It might cover the first part of the process, assuming that involves a potentially fatal “substance” and not just some substance-free voodoo (sources vary). But it doesn’t say anything about the reanimation part. I would interpret “whatever the consequences may have been” to mean only that attempted poisoning is covered, consistent with the principle that criminal statutes should be construed narrowly.

In any event, someone else also decided this wasn’t broad enough, because in 1864 two more paragraphs were added:

Art. 246. Poisoning is defined as any attack on a person’s life through the effect of substances that can cause death more or less promptly, in whatever manner these substances have been used or administered, and whatever the consequences may have been.

The use against a person of substances that, without causing death, produce a more or less prolonged lethargic state, is also considered an attempt on their life by poisoning, in whatever manner these substances have been used or administered and whatever the consequences may have been.

If, as a result of this lethargic state, the person was buried, the attempt is considered murder.

The second paragraph expands the law to cover substances that don’t cause death but only a “prolonged lethargic state.” Arguably the first paragraph covered that, because it only requires use of a substance that can cause death. If the victim just became lethargic, well, the consequences don’t matter. But maybe this paragraph was only meant to clarify that lethargizing is covered? That’s still not quite zombification.

But then there’s the burial part.

To the extent there is a “pharmacological case for zombies,” as Wikipedia puts it, that (or at least a theory for it) was laid out by Harvard ethnobotanist Wade Davis in his 1985 book, The Serpent and the Rainbow. (The basis for a 1988 Wes Craven movie I thought was scary and which, I was surprised to learn, got three out of four stars from Roger Ebert.) Davis went to Haiti to look into the case of Clairvius Narcisse, a man who died at a hospital in 1962 and was buried, only to later show up alive in his hometown. According to him, he had never been dead, just paralyzed. After his burial, he said, a bokor (evil priest) dug him up, drugged him again, and then enslaved him on a sugar plantation. He came to his senses and escaped after the bokor died. Or so he claimed.

After various adventures (but not being buried alive himself, like in the movie), Davis hypothesized that Narcisse and other alleged zombies had been drugged with naturally available toxins that can put someone into a coma. After they “die” and are buried, the bokor digs them up and uses a combination of drugs and the subject’s belief that zombies are real (and he or she is one) to control them. That seems semi-plausible, but you won’t be surprised to learn that significant questions have been raised.

Still, if there’s nothing at all to this theory, why is there a statute dating back to 1865 that makes it a crime to make a person so “lethargic” they might be buried by mistake?

The article says the extra paragraphs were added during the administration of President Fabre Geffrard, a Catholic who wanted to suppress “old superstitions” (the non-Catholic ones, that is). That suggests a similarity to other “witchcraft” laws we’ve discussed, which by the mid-1800s weren’t about punishing “real” witches but rather people who falsely pretended to be witches (or fortune-tellers, or necromancers, or clairvoyants, or phrenologists, or “crafty scientists” of whatever ilk). The law is at least some evidence, not that the practice is real, but that at least some people think it is, and the government wants to discourage that. This one doesn’t tell us zombies were actually being made, only that some people believed it was, and was done with poison, and they believed that before 1865.

So, technically, this statute doesn’t make it illegal to create a zombie. But it does make it illegal to poison someone, and defines that as “murder” if the person is buried as a result (no matter what might happen afterward). If zombies are created some other way, of course, that might be entirely different. I suspect there’s another law that would apply in that situation, but if this is a concern you really need a Haitian lawyer at this point.