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Yates v. State

Court of Appeals of Texas
171 S.W.3d 215 (2005)


Andrea Yates (defendant) and Russell Yates were married and had four children. Andrea had suffered from mental-health issues, including having visions and hearing voices, since she was a small child. As an adult, Andrea suffered from severe depression and once tried to commit suicide by taking an overdose of an antidepressant prescribed for her father. On numerous occasions, Andrea was admitted to a hospital’s psychiatric unit for treatment after suffering from a psychotic episode. Prior to her discharge after one of these admissions, a physician, who ranked Andrea as one of the five sickest patients ever seen by the physician, informed the Yateses that Andrea had a high risk of experiencing another psychotic episode if she had another child. The following year, the Yateses moved out of a converted bus they had been living in and into a house. Around that time, Andrea stopped taking her prescribed medications. Shortly thereafter, Andrea gave birth to a fifth child, a daughter. Four months later, Andrea’s father died. Her father’s death caused a rapid decline in Andrea’s mental health and functioning, and Andrea was admitted to a hospital for treatment and placed on suicide watch. Approximately one month later, Andrea was discharged and began an outpatient program. Andrea’s physicians recommended that someone stay with Andrea at all times and that she not be left alone with her children. Russell’s mother went to the Yateses’ home every day, where she observed Andrea in an almost catatonic state. Andrea failed to eat, did not respond to conversation, stared into space, and trembled. Subsequently, Andrea was re-admitted to the hospital for 10 days of treatment. After being discharged, Andrea’s functioning was better, but she remained uncommunicative, withdrawn, and without emotion. During follow-up visits with her physician, Andrea denied having any suicidal or psychotic thoughts. Approximately one month later, Andrea called 911 and informed the operator that she needed the police. Andrea also telephoned Russell and instructed him to come to the house. When the police officers arrived at the Yateses’ home, they found that all five children had been drowned by Andrea. [Editor’s Note: Andrea was charged with capital murder for the deaths of three of the five children. After a trial, the jury rejected Andrea’s insanity defense and found her guilty. Following the verdict but before the punishment phase, Andrea’s counsel learned that an expert witness for the state had presented false testimony. Andrea moved for a mistrial, which was denied by the trial court. The present case arose from Andrea’s appeal.]

Rule of Law


Holding and Reasoning (Nuchia, J.)

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