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The Andrea Yates Filicide Case and Its Facts

In the murders of three of her five children, Noah, John, and Mary, Andrea Yates was convicted of capital murder and sentenced to life in prison in March 2002. She had admitted to killing her other two children, Paul and Luke, and pled guilty to their murders (Denno, 2018). Yates said that Satan urged her to kill her five children in order to spare them from eternal damnation. The prosecution said Yates was legally sane at the time of the murders, meaning she recognized right from wrong, but her defense claimed she was insane (Denno, 2018). Yates had postpartum depression and schizophrenia, according to experts. Still, defense and prosecution testimony varied on the severity of her disease and whether it prevented her from recognizing the difference between right and wrong.

Later, a three-judge panel of Houston’s First Court of Appeals reversed Texas mother Andrea Yates’ capital murder convictions and ordered a new trial for the 2001 slayings of three of her children. The panel based its decision on misleading testimony by a key prosecution witness, psychiatrist Park Dietz, who was the only psychiatrist who testified during Yates’ trial (Denno, 2018). She was sane when she killed her children and had a history of postpartum depression. Yates is judged not guilty by reason of insanity on July 26, 2006 and is sent to a mental institution.

M’Naghten Rule and the Irresistible Impulse Test

Unlike the M’Naghten test, which focuses on intellect, the Irresistible Impulse test focuses on the intentional aspects of insanity. Various courts have battled with dealing with criminal defendants who, although understanding the wrongfulness of their conduct, lack self-control due to a mental illness or defect (Alden, 2020). Punishing a person who cannot control their behavior appears to be in contrast with the most fundamental principles of criminal justice. This tension is relieved by the shift toward volition. A jury may find a defendant not guilty by reason of insanity under the Irresistible Impulse test if the defendant suffered a mental condition or defect that caused them to conduct the object offense.

Although addressing a legitimate issue within the M’Naghten paradigm, the Irresistible Impulse test raises a number of practical concerns. First, unlike the cognitive component of the insanity argument, the intentional component of insanity has a weaker scientific foundation (Alden, 2020). In the absence of definitive scientific results, judging the validity of a defendant’s allegation becomes increasingly challenging. Furthermore, the Irresistible Impulse test may be too broad. Defendants suffering from psychiatric issues that do not entirely impair self-control may be acquitted of criminal responsibility.

Mental Illness as a Mitigating Factor

While it is undeniable that persons with mental illnesses are disproportionately represented in prisons, it is equally apparent that criminals’ mental states have no bearing on the harm they inflict. Murder victims are no less dead because schizophrenic or depressed perpetrators slew them than offenders with a perfectly normal mind, and intellectually challenged offenders no less violate rape victims than others (Alden, 2020). Because of their mental state, it is often considered that mentally ill perpetrators are less responsible for their actions. The aim to accommodate diminished guilt in a sentence while also protecting the public has created an apparently irreconcilable contradiction in the sentencing system.

However, the considered signs of the medical criterion do not yet give complete confidence in the insanity of the person who committed the crime since the presence of one of the diseases may not affect the intellectual or volitional elements. The leading criterion for determining insanity is a legal one, indicating the depth of the mental disorder, which does not allow a person to realize the social danger and consequences of their actions (inactions) and manage them. In addition, there are mental disorders that do not lead to insanity (Alden, 2020). With such conditions, a person cannot fully realize their actions’ actual nature and social danger (inaction) or direct them. That is, to establish a legal criterion of limited sanity and in case of insanity, the presence of one of its elements is sufficient. However, the listed mental anomalies only impact a person’s psyche when they deprive them of the opportunity to fully realize his act’s actual nature and social danger or guide thoroughly.

Mental Illness as a Valid Defense

It is hardly possible to raise the question of mitigation of punishment if the crime has taken on a particularly cruel or audacious character due to one or another mental anomaly. It is essential to consider the etiology of a mental disorder and not to mitigate the punishment of the guilty if this disorder results from an antisocial habit or immoral behavior (Alden, 2020). Reducing the sentence of mentally disabled persons is not always permissible since the reasons for committing intentional crimes are antisocial views and attitudes of the individual and not certain mental disorders.

The conclusion of a psychiatric examination may state that the defendant and the criminal have a mental disorder, which does not exclude normal sanity. If there is any disorder on the part of the nervous system or the psyche, the court may take this moment into account when assigning criminal punishment (Mallicoat, 2019). In accordance with this documentation, the judicial authority has the right to prescribe compulsory medical treatment and correction (Alden, 2020). However, inconsistency with the laws of psychiatry creates the impression that psychiatrists and psychologists are unreliable or that mental disorder is a purely subjective thing. The fact is that mental health professionals often cannot agree whether the accused fits the legal description of insanity, even if they can consistently diagnose him and establish the level of mental disorder.

A person who has been declared insane will be released when they are no longer mentally ill and will not pose a danger to others. In addition, according to American law, it is unconstitutional to keep such a person on treatment for a period longer than for which he would be convicted if recognized as mentally healthy (Alden, 2020). As a result, the terms of imprisonment when deciding on insanity may become shorter than in the case of a conviction for a crime. In part, such things explain the uncertainty of lawyers in the question of whether to use insanity when building a defense. Among prisoners in the United States, about 15% are with serious mental disorders. But only in 1% of felony charges (the most severe category of crimes) cases, the defense petitions the judge to declare the defendant innocent (Alden, 2020). And only in a quarter of this percentage of cases, the court grants lawyers’ request, despite the presence of obvious signs of mental disorder.

The Outcome of The Case

Andrea Yates’ trial is expected to be one of the most well-publicized criminal trials in US history. The shocking facts drew media and public attention to the case at first, but people’s interests shifted as time progressed. The importance of mental health in the criminal justice system was widely discussed in the media. The public and commentators were more sympathetic to Andrea and her mental health concerns in the run-up to the retrial in 2006. They appeared to be more tolerant of the idea that acute delusions may justify even the most heinous crimes. The public’s perception of Andrea changed dramatically between the 2001 event and the 2006 trials (VanDercar & Resnick, 2018). The NGRI decision was influenced by the date of her retrial. Andrea’s case was one of the first in the United States to employ the insanity defense in a high-profile case successfully.

It was the first time in a nationally broadcast criminal trial that post-partum depression was linked to psychotic episodes. Though it is doubtful that this instance influenced our opinions on mental health in the United States, it prolonged the conversation and served as a reminder of the progress accomplished. The tragic deaths of the Yates children in 2001, as well as the publicity surrounding the trial, brought postpartum depression and postpartum psychosis to national prominence. According to Postpartum Support International, a non-profit that raises awareness of the condition, while psychosis is rare, up to 20% of young mothers suffer from some kind of depression after having children (VanDercar & Resnick, 2018). The Yates case, as well as the cases of other mothers who killed their infants, has raised awareness of maternal mental illness and despair.

Andrea’s case would not have had the same impact if Dietz’s Law & Order thesis had not been developed. If the jury’s original decision stands, this case will join a long list of others that have attracted national attention (VanDercar & Resnick, 2018). On the other hand, Andrea had a chance in the court of appeals and a second opportunity in the trial court due to Dietz’s evidence. Andrea’s case was entrenched as one of the genuinely fascinating stories of the twenty-first century after the second shooting and the watershed judgment that followed.


Alden, A. L. (2020). Disorder in the court: Morality, myth, and the insanity defense (rhetoric, law, and the humanities) (1st ed.). University Alabama Press.

Denno, D. W. (2018). Andrea Yates: A continuing story about insanity. Fordham Law Legal Studies, 367–415. Web.

Mallicoat, S. L. (2019). Women, Gender and Crime, 3rd edition. Thousand Oaks, CA: Sage Publications.

VanDercar, A. H., & Resnick, P. J. (2018). The insanity defense: Historical precedent and modern application. Psychiatric Annals, 48(2), 95–101. Web.

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