Dr. Dietz concluded with reasonable medical certainty that Mrs. Yates was aware of the wrongfulness of her homicidal conduct (Carmickle, 2017).
Prosecution expert: Dr. Park Dietz, a forensic psychiatrist, was responsible for giving testimony that Yates was aware of her actions (Slobogin, 2003).
Texas Penal Code §8.01 : “It is an affirmative defense to prosecution that, at the time of the conduct charged, the actor, as a result of severe mental disease or defect, did not know that his conduct was wrong”
Prosecution argument: Yates failed to meet Texas’s definition of insanity because she knew that her conduct was wrong in the eyes of the law, society, and God (Slobogin, 2003).
Defense attorneys: were responsible for noting the erroneous testimony by the defense witness (Slobogin, 2003).
Police officers: They were responsible for arresting Yates and bringing her to trial (Slobogin, 2003).
Prosecution attorneys: They were responsible for attacking the “not-knowing” part of the insanity argument and bringing homicide charges (Slobogin, 2003).
Under the M’Naghten test, a person is excused only if they do not “know” about the wrongfulness of the act.
Arrest trial for capital murder
2006 Verdict: Texas Appeals Court was responsible for finding Yates to be not guilty and placing her in a mental institution.
Texas Jury: responsible for applying the M’Naghten test again and accepting the insanity defense
verdict of guilty overturned on appeal.
The Event: On June 20, 2001, Andrea Yates took the lives of her five children by drowning them, one by one, in a bathtub. Yates then called the police and her husband, Rusty Yates, and told them to come. When the police arrived, she openly stated that she had killed her children and showed the officers their dead bodies.
Andrea Yates, committing the act
Theoretical outcome: The defendant would have been acquitted
The jury was responsible for convicting Yates of murder and sentencing her to life in prison.
Texas jury: held the responsibility for applying the M’Naghten test and rejecting the insanity defense.
Defense attorneys: They were responsible for presenting the “guilty by reason of insanity” argument again and proving Yates to be severely mentally ill (Parnham, 2017).
Defense attorneys: George Parnham and Wendell Odom are entering a defense of not guilty by reason of insanity (Parnham, 2017).
- Two-pronged M’Naghten test:
- Whether a mental illness prevents the actor from understanding or “knowing” the nature of the acts she was committing (Parnham, 2017). The defense demonstrated that Yates had long suffered from a serious mental disorder.
- Whether even if the actor did “know” the nature of her actions, she understood that what she was doing was wrong (Parnham, 2017). The defense demonstrated that Yates did not understand that she was doing any wrong.
*Mens Rea Alternative
Theoretical outcome: The defendant would have been acquitted.
Theoretical outcome: The defendant would have been found guilty.
Primary defense expert: Dr. Resnick, a forensic psychiatrist, was responsible for evaluating Yates’ mental health and arguing that Yates has a severe mental disease (Carmickle, 2017). Specifically, he stated that Yates killed her children because she thought that doing so would ensure that they would go to heaven (Slobogin, 2003).
This method limits evidence of mental impairment to the question of whether the defendant possessed the necessary criminal intent to commit the alleged offense.
This method connects the defenses available to people with mental illness with those available to defendants who do not suffer from such illnesses (Parnham, 2017).
Dr. Resnik diagnosed Yates with a schizoaffective disorder based on her history of major depressive episodes, auditory and visual hallucinations, and paranoid delusions (Carmickle, 2017).
2005 Texas Code, § 8.01. Insanity. (a) Texas penal code chapter 8: General Defenses to criminal responsibility (2005).
Carmickle, R. L. (2017). Postpartum Illness and Sentencing: Why the insanity defense is not enough for mothers with postpartum depression, anxiety, and psychosis. Journal of Legal Medicine, 37(3–4), 579–596.
Slobogin, C. (2003). The integrationist alternative to the insanity defense: Reflections on the exculpatory scope of mental illness in the wake of the Andrea Yates trial. American Journal of Criminal Law, 30(3), 315-342.
Parnham, G. (2017). Beyond the Andrea Yates verdict: Mental health and the law. Texas Tech Law Review, 49, 847-860.