Texas Case Awakens Public to Postpartum Mental Illness

A notorious insanity defense case with more than one strange twist splashed across the pages of Psychiatric News in the early years of the last decade.

Andrea Yates of Houston had been treated for depression and postpartum psychosis before she drowned her five children in a bathtub in June 2001. At her trial in March 2002, a jury found her guilty of murder, despite her attorneys’ use of the insanity defense. The longer-term outcome was not so clear-cut, however.

“Yates was found guilty in a state that applies the M’Naghten Rule—an insanity definition formulated in 1843 and derived from English case law. That rule states that a person is ‘innocent by reason of insanity’ if ‘at the time of committing the act, he was laboring under such a defect of reason from disease of the mind as not to know the nature and quality of the act he was doing, or if he did know it, that he did not know that what he was doing was wrong,’ ” wrote reporter Mark Moran in the April 19, 2002, issue of Psychiatric News. “Because the jury was convinced that Yates knew that what she did was wrong, statutory law demanded a guilty verdict.”

The verdict highlighted both the strictness of the M’Naghten Rule in a case where Yates’s mental illness seemed obvious and the state-to-state variations in standards for an insanity defense.

APA members were concerned that Yates’s mental illness had not been seen by the jury as a mitigating factor.

“In the [John] Hinckley case, people criticized the [veracity] of the diagnosis,” Jeffrey Metzner, M.D., then chair of APA’s Council on Psychiatry and the Law, was quoted. “Not here. There was no disagreement that she was significantly mentally ill. The difference among the experts was whether she met the legal standard.”

Three years later, Yates’ conviction was overturned because Park Dietz, M.D., Ph.D., the psychiatrist for the prosecution, revealed that he had inadvertently given inaccurate testimony, wrote Ken Hausman in the February 4, 2005, issue.

During the original trial, Dietz “said that he had consulted on an episode [of the television show ‘Law and Order’] that concerned ‘a woman with postpartum depression who drowned her children in a bathtub and was found insane, and it was aired shortly before the [Yates murders] occurred.’ ”

Both defense and prosecution asserted that the show in Dietz’s statement had suggested to Yates both the means to kill her children and a way to avoid punishment though use of an insanity plea.

However, wrote Hausman, “On March 14, 2002, after Yates was convicted of murder but before the sentencing phase, Dietz informed the Harris County district attorney’s office that he had given an incorrect answer during cross-examination. He said that after the ‘Law & Order’ producers conducted a search of the show’s 269 episodes, they told him that they could find none in which a woman with postpartum depression had drowned her children in a bathtub.

“In an interview with Psychiatric News, Dietz expressed dismay at the ‘mischaracterizations’ of his testimony and his correction of it that have flooded the popular press. He emphasized that he did not testify about ‘nonexistent episodes’ of ‘Law & Order,’ but after reading scores of scripts for the show and watching nearly 300 episodes, he ‘misremembered’ and ‘confounded’ details of some of the episodes.”

“Dietz was and is a well-known and well-respected forensic psychiatrist,” said Metzner, now a clinical professor of psychiatry at the University of Colorado School of Medicine in Denver, in a recent interview. “When the error came to his attention, he handled it professionally and reported it. Forensic psychiatrists may make small errors from time to time, but they are usually caught and corrected in cross-examination.”

Dietz’s admission led to a retrial. Yates was found not guilty by reason of insanity in 2006 and was sent to the maximum security North Texas State Hospital in Vernon.

“The verdict from Yates’s second trial was welcomed by mental health advocates, including APA leaders,” wrote Mark Moran in the August 18, 2006, issue. “ ‘It is a great relief to hear that justice has prevailed,’ said APA Vice President Nada Stotland, M.D. ‘It’s heartbreaking that she was convicted in the first place.’ “

Public opinion had an important influence. “It’s rare that public opinion directly shapes the outcome of a criminal trial,” Paul Appelbaum, M.D., chair of APA’s Council on Psychiatry and the Law, told Psychiatric News then. “But I think this was one of those cases. After the first trial, in which a jury was so horrified by the crime that they gave short shrift to Yates’s insanity plea, there was a tremendous public outcry and discussion of the issues. This included extensive discussion of the nature of postpartum psychiatric disorders and their potential impact on criminal responsibility, even in states like Texas with narrow insanity standards.”

“There was nothing about the Yates case that changed the insanity defense,” said Metzner recently. That had already occurred two decades before—after the Hinckley case. “Probably the main effect of the trial was to provide more awareness publicly to postpartum depression and psychosis and the need for treatment, and that was a beneficial impact.” ■

For related information, see “Insanity Standards May Vary, But Plea Rarely Succeeds,”. “Insanity Plea Successful In Andrea Yates Retrial” can be accessed here. “Inaccurate Expert Testimony Wins Yates New Trial” is available here.