The case of Andrea Yates is well known, both because of the psychiatric aspects of the case and because of the accompanying issues regarding psychiatric testimony. It is illustrative of typical and atypical features related to forensic mental health assessment.
Who Was Andrea Yates?
Yates was a mother of five children, ranging in age from 6 months to 7 years old. She had suffered from depression (believed to be postpartum depression) and psychosis for some time and had been treated with anti-psychotic medication and antidepressants.
In 1999, she had attempted suicide by overdose, taking her father’s medication. In March of
2001, her father passed away and it appears she began to deteriorate from then on. She was hospitalized and released to outpatient care shortly before the homicides.
The Day of Murders
Two days before the killings, she was seen by her psychiatrist, who lowered her antidepressant medication but kept her off anti-psychotic medication. On June 20, 2001, after her husband had gone to work, Yates methodically drowned her five children. She then called 911 to report what she had done and called her husband at work. Yates was taken into custody, and the judge issued a gag order around the case.
Yates told examiners that she believed she was not a good mother, that the mark of the devil was hidden under her hair, and that her children would suffer in Hell. At the time of her arrest and incarceration, the jail psychiatrist reported that Yates had no insight into her mental illness, was “profoundly” depressed, and was psychotic (not in touch with reality). For example, she thought that the cartoons her children watched “were sending them messages” .
Andrea Yates reported to the psychiatrist that she began hearing voices after the birth of her first child. She also said she heard growling noises and reported “feeling” she was in the presence of Satan. Further, the children were not doing well (spiritually) and it was her fault. “She was convinced they were doomed to suffer in the fires of Hell.” It was the psychiatrist’s impression that Yates was “actively hallucinating [hearing voices] during the interview.” Yates advised it was her belief that “her children would be tormented and they would perish in the fires of Hell if they were not killed”.
Depression or Filicide?
Yates was diagnosed with major depression, with psychotic features, with onset postpartum (i.e., postpartum psychosis). The jail psychiatrist advised during trial that Andrea Yates was the sickest patient she had ever treated. A psychologist performed neuro-psychological testing on Yates while she was incarcerated. It was the psychologist’s opinion that she suffered from schizophrenia and a comorbid depressive disorder.
In a high-profile case like this, questions related to competency to stand trial quickly surface and the defense moved to have Yates found incompetent. In September 2001, a jury deliberated over two days after hearing expert testimony from both defense and prosecution experts, to determine if Yates had “a rational as well as factual understanding of the proceedings against her” and the ability to work with her attorneys.
Insanity or In-goes-sanity, out-goes crime!!
The jury found Yates competent to proceed with her legal case. A different jury would later hear the criminal case. There seemed to be no question that Yates was psychiatrically very ill. The question for the court was whether she met the criteria under Texas law for an insanity defense. The Texas statute requires that the person (as a result of a severe mental disease) did not know that what he or she was doing was wrong at the time the person did it.
Several defense experts testified that, in their opinion, Yates was unable to know right from wrong at the time she killed her children. One defense expert, Dr. Phillip Resnick, saw Yates several weeks after the homicides and again several months later. He noted that over time, Yates had memory alterations related to the events.
This is important, as the new or altered memories are “often more rational” because of clinical improvement in the individual, in this case because of appropriately prescribed medication. Dr. Resnick testified that it was “possible for an individual to believe that an act was illegal, but yet not perceive it as wrong” .
The case, to a great extent, centered on whether Yates understood that killing her children was considered a criminal act. She did. She understood that society would see her behavior as bad. But, as Dr. Resnick testified, she believed the homicides were the right thing to do as Satan was inside her and her children would suffer eternal damnation if she did not kill them. She did, however, know the difference between right and wrong. So even though she believed what she was doing was right in a moral sense, she knew what she was doing was wrong in a legal sense.
Dr. Park Dietz , a forensic psychiatrist, was the only expert in behavioral science who testified for
the prosecution. He examined Yates on November 6 and 7, 2001. By then she had been treated with antidepressant and antipsychotic medications. Dr. Dietz agreed that Yates suffered from a major mental disorder, schizophrenia, but disagreed that she met the criteria in Texas for an insanity defense.
In assessing Yates’s ability to appreciate the wrongfulness of her actions, he divided the crime into three phases: prehomicides, homicides, and posthomicides. In the prehomicide phase, he noted that Yates hid her plan from others and attributed the impetus for the killings to Satan. This negates the fact that she hid what she was planning, because carrying out the plan was necessary to save the children’s souls.
If she had told someone and was stopped, (in her mind) the children would suffer eternal damnation. He testified that if she believed her children were in danger or that Satan was inside her, she would have sought counseling or help in dealing with the situation. This line of reasoning imposes a rational standard on an irrational psychotic process.
Regarding the homicides phase, he noted that Yates admitted that she knew her actions were illegal, that she would be arrested, and that society would see her behavior as “bad.” Dr. Dietz opined if Yates actually believed she was saving her children, “she would have attempted to comfort them before the drownings.”
That may or may not be accurate. Once again, a rational standard was applied to a psychotic act. In the posthomicide phase, Dr. Dietz opined that covering the children’s bodies was evidence of “guilt or shame over her actions.” This is an opinion, not a fact.
It may be accurate, and it may not. Regardless, the emotion of shame or guilt after killing one’s children does not rule out having acted for their ultimate benefit.
Also, she had told the 911 operator that she had done “something wrong,” needed to be punished, and was ready to go to Hell. Yates had voiced a belief that her execution would kill Satan, but Dr. Dietz said she did not mention that at the time of the homicides. He gave his expert opinion that “at the time of the drownings, Ms. Yates knew her actions were wrong in the eyes of the law, wrong in the eyes of society and wrong in the eyes of God” .
Mental health and justice
Dr. Dietz testified at the trial that weeks before the homicides, Yates had watched an episode of Law & Order on television in which a woman drowned her children and was found not guilty by reason of insanity. The fact that Yates watched Law & Order was included in information from an expert who had evaluated her for competency to stand trial. It was later noted that no such episode aired.
Additionally, the prosecution used the nonexistent episode in cross-examining a defense expert
Finally, the prosecutor used the issue of the nonexistent episode during summation “She gets very depressed and goes to Devereux and at times she says these thoughts came to her during that month. These thoughts came to her, and she watches ‘Law and Order’; regularly she sees this program.
There is a way out!!
She tells Dr. Dietz, that there is a way out.” A producer of Law & Order contacted the defense to advise that no such episode had ever been made. When it was brought to Dr. Dietz’s attention that his testimony was false in regard to the Law & Order episode, Dr. Dietz wrote a letter, dated March 14, 2002, to the district attorney’s office advising of the situation. “I also wish to clarify that Mrs. Yates said nothing to me about either episode or about the Law & Order series.”
The court rectified this by giving a stipulation to the jury that, if Dr. Dietz would testify, his testimony would be that he was in error regarding the Law & Order episode. This was after the verdict, but before sentencing.
Yates was convicted of capital murder in the deaths of three of her children and sentenced to life in prison.
An appeal was filed on January 6, 2005, and the Texas First Court of Appeals overturned her conviction.
After a retrial, on July 26, 2006, Yates was found not guilty by reason of insanity for the deaths of three of her children, Noah, John, and Mary.