Inconsistently Heinous villains who are possessed/brainwashed, thus committing actions they probably wouldn't have done if it weren't for their problem.

Note: Villains who only do evil when they are possessed/brainwashed cannot count as Inconsistently Heinous due to failing the heinous standard to whoever is possessing/brainwashing them. However, if at least some of their worst acts were done without being brainwashed or possessed, then they can qualify.