The Lindsay Clancy Case and the Limits of the Insanity Defense

This house was used in the film Anatomy of a Murder as the home of the character Paul Biegler (played by Jimmy Stewart). Ishpeming, Michigan. Courtesy of Chad Johnson, Lake Linden, MI, USA, via Wikimedia Commons.

Lindsay Clancy, 35, a resident of Duxbury, Massachusetts, is currently facing charges for the murders of her three children on January 24, 2023. She is accused of strangling her daughter, Cora, five, her son, Dawson, three, and her infant, Callan, eight months. Clancy is pleading not guilty.

The alleged murders took place at Clancy’s home in Duxbury, Massachusetts. According to her and her husband’s stories, her husband, Patrick Clancy, was running errands in Kingston, Massachusetts — about 15 minutes from their home — while Clancy committed the murders. Assistant District Attorney Jennifer L. Sprague alleged that the actions were premeditated and that Clancy sent her husband out to run these errands so she could commit the crimes in his absence.

“She planned these murders, gave herself the time and privacy needed to commit the murders, and then strangled each child in the place where they should have been the safest — their home,” Sprague declared at Clancey’s arraignment.

Clancy’s defense attorney, Kevin Reddington, has portrayed her actions as being due to severe postpartum mental health struggles. He has pointed to the fact that after Clancy allegedly committed the murders, she attempted to commit suicide, which left her permanently paralized from the waist down.

 One of the reasons this case has garnered national attention is that it raises many questions about the role of postpartum depression in Clancy’s decision-making and the legality of PPD as a defense of insanity in the courts.

Reddington has announced plans to use a similar defense method in Clancy’s trial. Specifically, he has said he will use evidence proving she was overmedicated and suffering from PPD and psychosis at the time of the alleged murders, contributing to her crippling mental health. Multiple criminal defense lawyers have supported Reddington’s argument, saying it will make a strong case for Clancy’s mental incompetence.

Reddington is also arguing that the trial should be bifurcated into two distinct stages. Bifurcated trials are often permitted when there is a division of accountability and liability.

While bifurcated trials are not a constitutionally guaranteed right, the argument against a regular trial has been raised by her defense team because two of Clancy’s constitutional rights will be at odds: her Fifth Amendment right against self-incrimination and her Fourteenth Amendment right to have the opportunity to present evidence about the state of her mental health would be in jeopardy if both presented in one trial.

The decision to bifurcate the trial is within the judge’s discretion. Sprague urged the judge to reject Reddington’s motion, arguing Clancy does not have the right to such distinctions. “You’d be having duplicate trials for no reason if we were to proceed in a bifurcated manner,” she said.

This case raises multiple legal, ethical, and moral questions about what PPD is, and if, or how, it contributed to Clancy’s actions. While many women experience heightened emotions after giving birth, often referred to as “baby blues,” women who suffer from PPD often experience more severe and persistent mood episodes. Many women with PPD experience unwanted and intrusive thoughts of causing harm to their infant. Though they have absolutely no intention of acting on these thoughts, mothers often fear that they may somehow lose control.

PPD is used as an argument under the insanity defense, usually in circumstances where mothers harm their children, such as in this case. Most states initially allowed this application of the defense through the M’Naghten Rule or similar tests used to assess the validity of the insanity plea. This was the first legal test of criminal insanity, dating back to 1843. Simply put, the M’Naghten Rule is a legal standard, also known as the “right-wrong” test, that determines whether a defendant can be held criminally liable by reason of insanity.

Presently, only 17 states continue to use variations of the M’Naghten test, while the majority of states, including Massachusetts, have switched to follow the broader, newer Model Penal Code insanity test. In Massachusetts, the basis for the insanity defense stems from the case of McHoul v. The Commonwealth. James N. McHoul, a patient of Boston State Hospital at the time, was convicted and sentenced for assault with intent to rape, and breaking and entering with intent to commit rape. The case updated Massachusetts insanity law by replacing the M’Naghten Rule with a state-specific Model Penal Code that places the burden on the prosecution to prove the defendant’s sanity beyond a reasonable doubt.

According to the National Library of Medicine, almost 50% of mothers with PPD are never diagnosed. This case is tragic, but hopefully brings light to the underresearched topic of PPD and postpartum psychosis, to help support new mothers, diagnose postpartum depression and psychosis earlier, implement supportive measures, and prevent cases such as that of Lindsay Clancy from occurring.