The stability of the orbits around the sphere of influence of the secondary body in the circular restricted three-body problem is discussed. This orbit is called “Pseudo Orbit” here. Though there exists a stability limit for the inclination of the pseudo orbit, the whole story of the instability was not resolved. In this paper, it is shown at first that the out-of-plane motion of the pseudo orbit causes disturbances in the in-plane motion by the method of virtual energy. Then, it is shown that the disturbances are governed by the Mathieu’s equation which has the periodic coefficient, and the rigorous mathematical property of the instability of the pseudo orbit is presented.