58 Current Women’s Health Reviews, 2010, 6, 58-62
Schizophrenia and Filicide
Teresa Ostler* and Sandra Kopels
School of Social Work, University of Illinois at Urbana-Champaign, USA
Abstract: This article examines the contexts associated with the rare but serious issue of women with schizophrenia who
kill their children (filicide). It reviews some of the legal issues that arise in the aftermath of these filicides and discusses
therapeutic interventions.
Keywords: Schizophrenia, neonaticide, infanticide, filicide, insanity, unfit to stand trial, guilty but mentally ill.
INTRODUCTION
Predicting which women with schizophrenia are at risk
for filicide is extremely difficult, since the incidence is low
[1]. This article explores different types of filicide by women
with schizophrenia and reviews legal issues and clinical
interventions.
CONTEXTS OF DIFFERENT TYPES OF FILICIDE
The term filicide includes both neonaticide (the killing of
a baby in the first day of life) and infanticide (the killing of a
baby in the first year of life). The killing of an older child is
a third type of filicide.
Neonaticide is closely associated with psychotic denial of
pregnancy in women with schizophrenia [2 and article by
Solari in this issue]. Women who have psychotically denied
pregnancy may have intense psychological conflicts and
fears about pregnancy, sexuality and dependency [2]. Unpre-
pared emotionally for labor or delivery, the newborn baby
may be harmed either by the mother failing to seek immedi-
ate medical help at birth or by her battering the baby or
attempting to silence the babies’ cries [2].
Infanticide is associated with post partum psychotic
illness [3 and article by Vigod and Ross in this issue]. Most
at risk are women whose psychosis is untreated and whose
symptoms directly involve the baby. Infanticide may be
preceded by hearing voices that the baby will be saved from
disaster only by death or that someone will kidnap the baby
[4]. More rarely, it is preceded by the delusion that the baby
is defective [5] or evil [4].
Multiple factors, including lack of support and fear of
abandonment from a partner usually interact to increase
the risk of infanticide. Clinicians should be alert to lack of
support and fear of abandonment from a partner [6]. Other
factors to monitor include: hostility or apathy towards the
baby, anxiety that leads to excessive rumination, failure to
bond with the baby, projection of adult feelings onto the
baby, and difficulty in relating to the baby [7].
*Address correspondence to this author at the School of Social Work,
University of Illinois, 1010 West Nevada Street, Urbana, IL 61801, USA;
Tel: (217) 244-5233; Fax: (217) 244- 5220; E-mail: ostler@illinois.edu
1573-4048/10 $55.00+.00
Killing an older child is usually preceded by active
psychotic symptoms, [8] but multiple factors, such as stress,
impulsive behavior, an untreated illness, and poor support,
also contribute [7, 9].
Mothers who are psychotic and kill an older child differ
in important ways from women who kill when not psychotic
[9]. For women with psychosis, the filicides are generally
more violent and may involve a gun or knife, whereas
filicides that are committed by non-psychotic women are
more likely to involve smothering a child. Women who are
psychotic are typically older and better educated, and the
children they kill are older, compared to those of non-
psychotic women. Women with psychosis who kill a child
rarely try to evade detection.
In the aftermath, women with severe mental illness
who have committed filicide express deep regret about the
killings [6] and experience intense self-judgment and hate
[10]. In interviews conducted years after the filicides oc-
curred, they express disbelief that they were capable of kill-
ing their children and remain highly distressed by the
thought that they might be a danger to other children. Recall-
ing and talking about the killings is difficult. For these moth-
ers, an acknowledgement of their illness appears to be an
important part of their attempts to come to terms with their
actions. Ongoing relationships with surviving children and
other family members are seen by the women as crucial to
their rehabilitation [10].
Depression is an important risk factor [7]. A child’s per-
sistent crying, increased stress, isolation, domestic violence,
substance abuse, and a history of personal childhood mal-
treatment are all stressors that can increase risk of filicide in
depressed women with schizophrenia. For some women, the
persistent negative and self-defeating thoughts about the self,
others and the future that are characteristic of depression
may contribute to hopelessness and increase risk for suicide.
In this situation, a woman may decide to kill her children as
well as herself so as to not leave them behind.
Risk of suicide is high after the killing and increases
during the time that a woman awaits her trial [11] and can
recur at the anniversary of the child’s death or on the child’s
birthday [7].
© 2010 Bentham Science Publishers Ltd.
Schizophrenia and Filicide
LEGAL AFTERMATH
Many countries have passed laws to cover situations
where mothers kill their infants within the first year of the
infants’ lives. These countries use the British Infanticide Act
as their model. The British Infanticide Act treats infanticide
by a mother as a less severe crime than other homicides, and
is premised on the belief that a mother who kills her child
does so because her mind has not fully recovered from the
effects of giving birth [12]. The British Infanticide Act no
longer differentiates between neonaticide and infanticide; the
1922 version of the law was limited to mothers who kill the
“newly born” while the current law, enacted in 1938, ex-
tended its coverage to children under the age of 12 months
[12]. Upon a showing of a postpartum mental disorder,
mothers who kill their children during the first year of life
are convicted of manslaughter, rather than murder, and gen-
erally receive lesser punishments, ranging from probation
and psychiatric treatment to life imprisonment [13]. The
British Infanticide Act has been replicated in varying forms
in at least twenty-two other countries, including Australia,
Canada, Colombia, Finland, India, and Korea [14].
The United States has not enacted an Infanticide Act, nor
is there a uniform approach to cases in which mothers kill
their children. Instead, each individual state is free to choose
its own approach to filicide cases. Moreover, within each
state, individual prosecutors have the discretion to choose
whether to prosecute the mother at all and for which specific
crimes. In most situations, the prosecutor will charge the
mother with some degree of murder, based on factors such as
the mother’s intent, the heinousness of the crime, the public
outrage expressed, the prosecutor’s personal belief system,
the potential jury’s sympathy for the mother, the availability
of proof, and the likelihood of conviction. Prosecutors must
also determine whether they can meet their burden of proof,
the “beyond a reasonable doubt standard” necessary for con-
viction in all criminal cases.
As in all crimes, a criminal act is accompanied by mens
rea, the state of mind that indicates culpability for a particu-
lar crime. If the prosecutor chooses to prosecute a mother for
killing her child, the mother’s mental condition becomes
important to determine her intent. Additionally, her mental
state may serve as a bar to trying her for the crime or provide
her with a total or partial defense to the crime.
COMPETENCE TO STAND TRIAL
A mother who kills her child as a result of her mental
illness may or may not be competent to stand trial. To be
competent to stand trial, individuals must both understand
the nature and purpose of the charges filed against them and
be able to assist their attorneys in defending against these
charges. While mental illness does not necessarily equate
with being incompetent to stand trial, persons with
schizophrenia and other psychotic disorders have the highest
rates of impaired ability to stand trial when compared to all
criminal defendants, including those with other forms of
mental illness [15].
Upon their arrest, mothers who kill their children are held
in jail as they await trial, often receiving no treatment for
their illness. The severity of their mental health symptoms
may ebb and flow while incarcerated. In most states, unfit
Current Women’s Health Reviews, 2010, Vol. 6, No. 1 59
defendants can be ordered to mental health facilities for
treatment of the underlying mental illness so that they will
become fit to stand trial
Some mothers who have killed their children experience
an improvement in their mental condition over time. Others
will voluntarily accept psychotropic medication, their symp-
toms will abate, and they will become fit to stand trial. Still
other mothers might be forced to take medication involuntar-
ily while in jail because of agitation or violent behavior. If
their symptoms improve to the point where the mothers can
understand and cooperate in their defense, mothers face the
very real possibility that they will stand trial for murder and
receive punishment if found guilty. As their symptoms im-
prove, mothers also may become more depressed as they
realize that they killed their children and begin to process the
consequences of their actions.
There are a small proportion of persons whose mental
conditions will not improve and they may never be deter-
mined competent to stand trial. A person who is unfit to
stand trial cannot be held indefinitely, however. Due to the
presumption of innocence under the law, the United States
Supreme Court stated that due process requires that persons
charged with criminal offenses who are held solely because
of their incapacity to proceed to trial cannot be held more
than a reasonable period of time, the time necessary to de-
termine whether there is a substantial probability that they
will attain that capacity in the foreseeable future (Jackson v.
Indiana, 1972) [16]. In almost every US state, once defen-
dants have been found to be incompetent to stand trial with-
out the substantial probability that they will become fit
within a reasonable period of time, state statutes require
them to be released and their charges dismissed. If they meet
the standard for civil commitment, they can be transferred to
a psychiatric hospital [17].
INSANITY AS A DEFENSE
Competency to stand trial is based on the mental state of
the defendant at the time of trial. The legal definition of “in-
sanity” relates to the mental state of the defendant at the time
the crime is committed. A finding of insanity allows a person
who commits a crime to be relieved from culpability for the
crime. Insanity is a legal concept that requires more than the
individual merely having a clinical diagnosis; persons can be
mentally ill and not be legally insane. Instead, to claim in-
sanity as a defense or to be “insane” means that an individual
meets all of the criteria that the state requires in the legal
definition of insanity that it adopts.
Mothers with schizophrenia who kill their children may
have been insane when they committed their crimes. There
are two main formulations of the insanity defense currently
in use. The first of these formulations is known as the
M’Naghten test, derived from an 1843 English case. The
M’Naghten test asks whether the defendant “was laboring
under such a defect of reason, from disease of the mind, as
not to know the nature and quality of the act he was doing;
or if he did know it, that he did not know he was doing what
was wrong” [18]. The M’Naghten rule finds defendants in-
sane only if they can prove that because of their mental con-
ditions, they either did not know right from wrong when they
committed the crime or did not understand the nature and
60 Current Women’s Health Reviews, 2010, Vol. 6, No. 1
quality of the act [19]. The M’Naghten test is considered to
be a purely cognitive test because it only focuses on the de-
fendant's knowledge and not on her ability to control behav-
ior [20]. Cognitive tests ask whether, at the time of the
crime, the defendant’s mental condition prevented him or her
from knowing, appreciating, or understanding the nature of
his or her conduct or that it was morally or legally wrong
[21]. A mother with schizophrenia who killed her children
would have to prove, through psychiatric testimony, that her
delusional system prevented her from comprehending that
killing her children was wrong.
For example, in the case of Andrea Yates, the Texas
mother who in 2001 drowned her five children, aged 7 years
to 6 months, a number of mental health professionals testi-
fied at her trial. All of the professionals on both sides of the
case agreed that Mrs. Yates had a severe mental disease at
the time of the killings and knew that her conduct was
against the law. However, the psychiatric testimony differed
over whether Andrea’s mental condition rendered her able to
understand the wrongfulness of her conduct.
Dr. Park Dietz, the sole psychiatrist on behalf of the
prosecution, testified that Andrea knew that her conduct was
wrong. He based his opinion on: 1) Andrea’s belief that Sa-
tan put the thoughts about drowning her children in her mind
and encouraged her to drown them; 2) Andrea decided to
conceal her beliefs about Satan and his influence, her
thoughts of harming the children, and her plan to drown
them from everyone; 3) Andrea believed that killing her
children would be a sin; and 4) Andrea knew when she killed
her children that society and God would judge her actions as
“bad” [22].
Alternatively, Dr. Phillip J. Resnick, the primary forensic
psychiatrist for Yates’ defense, testified that Andrea did not
know the wrongfulness of her conduct. Dr. Resnick based
his opinion on 1) Andrea’s delusional belief that it was right
to drown her children because they were not being raised
righteously and they would burn in hell if she did not drown
them while they were still innocent; 2) Andrea expected to
be executed by the State and because Satan was within her,
Satan would also be executed; 3) Andrea suffered from
command hallucinations to kill her children yet she did not
kill them two years earlier because she did not believe it was
in her children’s best interests to die at that time; instead, she
attempted suicide twice, rather than harming her children..
When her psychotic symptoms recurred later, she delusion-
ally believed that the time was then right to kill the children
to save their souls; 4) Andrea made no effort to hide her
crime in spite of the delusional belief that TV cameras were
monitoring her home. After killing her children, she called
the police, remained at the crime scene and requested pun-
ishment for her actions; and 5) Andrea had no motive for
killing her children other than her belief that she was saving
their souls. She confessed that she was not angry with them
because they had done nothing wrong [22].
The jury that deliberated in Yates’ trial found her guilty
of murder. On appeal, the verdict was overturned and a new
trial began. In the new trial, Dr. Resnick again testified and
also provided rebuttal testimony to Dr. Dietz’s testimony.
The second jury recognized that Andrea’s delusional system
caused her to think that what she did was right [22].
Ostler and Kopels
The second major definition of insanity is that of the
American Law Institute’s Model Penal Code, which provides
that “a person is not responsible for criminal conduct if at the
time of the conduct as a result of mental disease or defect he
lacks substantial capacity either to appreciate the criminality
[wrongfulness] of his conduct or to conform his conduct to
the requirements of law” [23]. The Model Penal Code
(MPC) contains two prongs: it combines the cognitive com-
ponent of the M’Naghten test with a volitional or control
component. A volitional test asks whether, as a result of a
defendant’s mental condition at the time of the crime, he or
she was unable to control the conduct or to conform it to the
requirements of the law [24]. In a jurisdiction that uses the
MPC test, a mother with schizophrenia who killed her
children would have to prove, through psychiatric testimony,
that her delusional system was so powerful that she was
unable to control her actions when she took her children’s
lives. The MPC formulation is considered to be the more
liberal test because the satisfaction of either the cognitive
or the volitional prong is grounds for an insanity defense
[19].
Under the defense of diminished capacity, a defendant
who suffers from an abnormal mental condition, which is
insufficient to meet the definition of insanity, can use the
mental condition to negate the question of whether she pos-
sessed the requisite mental state for the charged offense.
Based on psychiatric testimony, a court could find that, al-
though a mother with schizophrenia was not suffering from a
mental condition that meets the legal definition of insanity,
her mental condition affected the intent aspect of the crime,
rendering her incapable of premeditation, deliberation, or
malice [24]. The diminished mental condition is taken into
consideration in terms of sentencing and may result in the
mother being convicted of relatively lesser offenses that re-
sult in imprisonment, rather than commitment to a mental
institution [13].
Some states have also created the Guilty but Mentally Ill
(GBMI) verdict in which the judge or jury may find that the
mother with schizophrenia has a mental illness but is not
legally insane at the time of the offense. The illness is not
serious enough to justify the mother’s acquittal for the crime,
but still warrants a need for treatment. When an individual
receives a verdict of GBMI, she is found guilty of the of-
fense, is sentenced criminally for her crime and may or may
not receive treatment for her mental illness, depending on
state law [25].
Some mental health professionals testify as expert wit-
nesses in the trials of women who kill their children. Their
role is to evaluate the particular defendant’s mental state at
the time of the crime and offer expert opinion on the
mother’s ability to understand right from wrong or to formu-
late the intent to commit the acts. Expert witnesses are paid
by the prosecution, defense, or the court to provide testi-
mony that will aid the trier of fact in understanding issues
related to diagnosis, prognosis, mental illness and other
aspects of the case. Experts can offer opinions based on
hypothetical situations, interpret facts, and draw conclusions
[26].
Clinicians who treat mothers who kill their children
should not function as expert witnesses. Instead, treating
Schizophrenia and Filicide
clinicians may serve as fact witnesses, providing an account
of the services they provide and the results of such services.
Treating clinicians are concerned with the development of
the treatment relationship and the improvement of their
clients’ mental states. As their relationships develop with
their clients, clinicians may not be sufficiently objective to
act as experts in their clients’ cases [27]. Although some
courts may allow the treating clinician to testify as an expert
witness, clinicians are encouraged to resist serving in both
roles due to potential conflicts of interest [27].
Clinicians may accompany their clients to court through-
out the legal process and may have to deal with the anxiety,
stress, depression or exacerbation of symptoms caused by
court appearances. Even if they only testify to the facts about
the treatment relationship, clinicians still need to understand
legal issues related to filicide. Clinicians should keep in
mind that the law does not distinguish between depression,
schizophrenia and other types of mental illnesses nor does it
consider previous hospitalizations, medication regimes or
treatment. Instead, when mothers kill their children, the legal
questions are straightforward. Did the mother intend to kill
her children? Did she act in a manner that demonstrates pre-
meditation? Do her mental or emotional problems rise to the
level of insanity under the law? Should she be punished
criminally or excused from responsibility for her acts be-
cause of her mental condition?
CLINICAL INTERVENTIONS
A significant number of at-risk women with mental ill-
ness come to the attention of mental health professionals
before a filicide occurs [28]. Potential risks might be de-
tected by health professionals who come into contact with
mothers in the peripartum period. Since risk for neonaticide
is higher in women with schizophrenia who psychotically
deny that they are pregnant, clinicians should pay close at-
tention to mothers’ responses and consider the pros and cons
of psychotropic medication [2].
Acute psychotic symptoms in the postpartum period
or later are an important context for neonaticide and for
filicides involving older children, especially if the symptoms
directly involve the children. Mental illness symptoms that
clinicians should be alert to include: aggressive, violent or
unpredictable behavior, presence of suicidal or homicidal
ideation, deteriorating judgment, presence of command
hallucinations, and rapidly changing mental states [29].
Screening for symptoms of depression is imperative
in the peripartum period and later as this is an important
context in which filicide and suicide may occur. Women
with schizophrenia who have a family or personal history of
depression are more prone to become depressed postpartum,
so inquiring into a mother’s history can be critical. Poor
support, isolation, marital violence, a baby with a difficult
temperament, financial difficulties, and high stress levels
can also increase risk. When speaking to pregnant women
or mothers, clinicians should ask mothers directly about
whether they have thoughts of harming their children. If
a mother is suicidal, asking about plans for the children is
imperative. Clinicians should keep in mind that women may
be reluctant or ashamed to reveal symptoms they are experi-
encing. This can occur out of paranoia or from the shame
Current Women’s Health Reviews, 2010, Vol. 6, No. 1 61
and guilt of having symptoms at a time when a mother
should be happy.
When risk is unclear, a parenting assessment can estab-
lish what risks a mother may pose as a parent and what in-
terventions could remediate the risks [30 and see article by
Seeman on parenting in this issue].
For therapeutic change to occur, risk factors need to be
systematically targeted, starting with the most urgent ones
first. What interventions are set in place will vary depending
on what risk factors are present, on their mutability, and on
mother’s willingness and ability to engage in treatment. Sta-
bilizing the mother’s symptoms and helping her to manage
them through pharmacotherapy are central. Building the
mother’s support network is also imperative. Clinicians can
start by helping a mother to identify who is realistically or
potentially available in her network. If women are isolated or
if their families are not supportive, identifying community
supports will be important. Support groups provide a setting
where risks can be monitored and where mothers can meet
mentors and other mothers. Individual psychotherapy can
address emotional problems (see article by Miller on psycho-
therapy in this issue). When a mother’s experiences of
trauma negatively affect parenting, parent-child psychother-
apy can help a mother to better appraise signals of danger to
herself and her children while mobilizing her capacity for
self-protection and protection of the children [31]. Crisis
intervention, including inpatient hospitalization, may be
needed if a mother becomes suicidal (see article in this issue
by Spielvogel and Lee on inpatient treatment). Having a plan
in place for alternate care for her children is essential.
Treating a woman with schizophrenia who has killed a
baby or child can be challenging. Clinicians should be aware
that women in this situation face an arduous and painful
pathway. Once arrested, a mother’s life will be filled with
court appearances and incarceration. She may receive no
treatment for her illness. Relationships with her family and
partner may breakdown and the woman may experience in-
tense self-hate, guilt, remorse, and grief while likely facing
extreme stigma and isolation.
Treatment requires a multifaceted approach. Stabilizing
and treating a mother’s symptoms with pharmacotherapy is
typically followed by individual psychotherapy to address
issues of guilt, self-hate, remorse, and grief. Clinicians need
to communicate honestly with mothers and strive to be ob-
jective. Crisis intervention, including inpatient hospitaliza-
tion, may be necessary if a mother becomes seriously de-
pressed or suicidal. Clinicians should be aware of strong
counter-transference responses, including anger and rescue
wishes, as they can influence the ability to treat [32].
In both preventive and interventive efforts, clinicians
should keep in mind that mothers will be more likely to seek
help and to stay in treatment if help is offered in a nonjudg-
mental way. If clinicians can tolerate intensively negative
feelings, mothers will be more likely to reveal any frighten-
ing thoughts they may have.
CONCLUSION
Filicide is extremely rare in women with schizophrenia,
but it receives high media attention. Clinicians who treat
62 Current Women’s Health Reviews, 2010, Vol. 6, No. 1
mothers who have killed a child will need to understand le-
gal issues mothers will face. They will also need to know the
components of a comprehensive treatment approach. This
approach will include pharmacotherapy, individual psycho-
therapy, a strengthening of support networks, and crisis in-
tervention. Finally, clinicians should know the risk factors of
different types of filicide. The earlier risks are detected, the
more opportunity there is for prevention.
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