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Yates v. State

(2005)

Texas Courts of Appeals - 171 S.W.3d 215

tl;dr:

Andrea Yates drowned three of her children and presented an insanity defense, but later it was discovered that the State's expert witness presented false testimony.

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Facts & HoldingYates v. State case brief facts & holding

Facts:Andrea Yates was convicted of drowning three of her children...

Holding:The court's final holding is that the trial court erred...

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Yates v. State | Case Brief DeepDive
Majority opinion, author: SAM NUCHIA, Justice.
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Andrea Pia Yates was convicted of drowning three of her children and sentenced to life in prison. She presented an insanity defense, which was rejected by the jury. Later, it was discovered that the State's expert witness presented false testimony. Yates challenges the factual sufficiency of the evidence and the use of false testimony violating her right to due process. Yates had a history of mental illness and had been hospitalized multiple times. Her psychiatrist warned her and her husband about her high risk of a psychotic episode if she had another baby. Yates stopped taking her medication and gave birth to her fifth child. After the death of her father, she was admitted to a hospital and discharged with a recommendation that someone stay with her at all times and that she not be left alone with her children. Yates was readmitted to Devereux Hospital after exhibiting symptoms of catatonia, delayed response, staring into space, trembling, and self-harm. She was prescribed Haldol and discharged, but her condition did not improve. Andrea refused electroconvulsive therapy. On June 20, 2001, Andrea called 911 and told Yates that their children were hurt. When the police arrived, they found four of her children dead and the fifth child, Noah, floating face down in the bathtub. At trial, multiple mental health experts testified about Andrea's mental illness. The State's expert testified that although Andrea was psychotic, she knew that what she did was wrong. During cross-examination, Andrea's counsel asked the expert about his consulting work with the television show "Law & Order," which aired an episode about a woman with postpartum depression who drowned her children in the bathtub and was found insane, shortly before the crime occurred.

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