Vanderbilt Law Review


Georgia L. Sims

First Page



When Andrea Yates drowned her five children, she believed she was preventing Satan from infiltrating their souls. Rusty Yates blamed both the mental health system and the criminal justice system for his wife's actions and also for her initial conviction. Andrea Yates suffered from post-partum depression and psychosis; had attempted suicide twice; had been hospitalized on several occasions for psychiatric treatment; and was found not guilty by reason of insanity in her 2006 retrial.' Although Yates likely will spend the rest of her life in a mental institution, she will receive mental health treatment throughout her time at the facility. Yates would have spent her life in prison without access to comparable mental health treatment if her original conviction had been upheld. Yates escaped this fate through her subsequent insanity verdict, but many individuals who suffer from mental health problems and who are convicted of crimes and incarcerated in the United States are not so fortunate.

Reaching a result contrary to Yates's insanity verdict, the Supreme Court upheld the first-degree murder conviction of Eric Clark in 2006. Clark shot and killed a police officer because he believed that aliens impersonating government agents were taking over Flagstaff, Arizona, and bullets were the only way to stop these aliens. The trial court found him guilty of first-degree murder, and he will serve a life sentence in prison even though the trial judge noted that Clark "was indisputably afflicted with paranoid schizophrenia at the time of the shooting." The Court held that states may choose how to define insanity because "due process imposes no single canonical formulation of legal insanity."' Affording this interpretive freedom to the states is necessary, according to the Court, because mixing "legal concepts of mental illness" and "medical concepts of mental abnormality" creates a great deal of disagreement among medical professionals. The Court also held that preventing a defendant from relying on mental illness to negate the specific intent of the crime was not a due process violation.'