In 2001, the media reported on the horrific drowning death of 36-year-old Andrea Yates’s five children. Andrea Yates, a suburban Houston resident and mother of five, was under a doctor’s care for post-partum depression. In the space of an hour, she drowned all five of her children in the bathtub. The prosecution charged her with murder; her defense was an insanity plea, claiming that only someone who is insane would commit such acts on her own children.
Insanity Defense
Scientifically, Andrea Yates was probably insane. Nonetheless, the law is not contingent on a scientific definition of insanity; instead, the issue is whether Andrea Yates was legally insane. By framing the issue as a legal question, science, through prominent, is not the central authority. Rather, the law governs whether a defendant is held not guilty by reason of insanity.
M’Naughten Test
In determining insanity as a legal issue, the Texas Penal Code follows the M’Naghten Test. This test determines sanity by questioning whether the defendant, at the time the act was committed, comprehended right from wrong. A defendant would successfully plead insanity if the facts surrounding the event demonstrated that mental illness prevented the defendant from understanding that his or her actions were of a wrongful nature.
Moreover, the court in Graham v. State from 1978 stated: “The purpose of the insanity defense issue is to determine whether the accused should be held responsible for the crime, or whether his mental condition will excuse him from responsibility.” Thus, the issue is whether the defendant had a culpable state of mind, not if the defendant committed an unlawful act.
Affirmative Defense
An insanity defense is an affirmative defense, meaning that the burden of proof falls onto the defendant. It is the defendant’s job to then demonstrate, by a preponderance of the evidence, that the defendant lacked the proper state of mind to commit the act because the defendant satisfies the M’Naughten Test. This is a high standard. Often, both the defense and prosecution will provide psychological testimony, which would be compelling. However, ultimately it is the judge and jury’s charge to rule if the defendant is legally insane.
Andrea Yates Case
In determining insanity, there were some issues. Andrea Yates called the police after she killed her children. This suggests that she understood right from wrong. Why would she call law enforcement if, in her mind, she did nothing wrong? Ultimately, though, defense counsel provided evidence Yates followed the religious teachings of a satanic cult that preached biblical prophecies. A forensic psychologist testified that Yates believed that her death, after the death of her five children, would be fulfilling a biblical prophecy. At trial, the court rejected the insanity plea based on Yates calling the police. On appeal, the court accepted the explanation of biblical prophecy and were compelled by Yates’s schizophrenic diagnosis.
If you are accused of a crime, you need a lawyer who will aggressively defend your rights. You also need a lawyer who is experienced and knowledgeable in Texas law. Contact the law firm of Christopher Abel, a board-certified criminal defense attorney.
(image courtesy of Henry Hering, photographer (1814-1893))