Proof by Atrocity

The logic that makes the crime its own excuse

On the afternoon of September 4, in a Plymouth County courtroom, the Lindsay Clancy jury sent out its last note: "It is with a heavy heart that we report we are unable to come to a unanimous decision, and we will not be able to."¹ Seven weeks of trial, some forty hours of deliberation across seven days, three declarations of deadlock, and one reading of the Commonwealth's venerable dynamite charge had produced no verdict, and at 2:23 that afternoon Judge William Sullivan declared a mistrial.² By evening the public knew what it is never supposed to know. The jury had stood eleven to one for acquittal by reason of lack of criminal responsibility, the lone dissenter was a man, and the country knows the number because the defendant's own lawyer announced it at a press conference, with commentary.³ I had drafted this essay to run after a verdict, in either direction. The jury declined to supply one, and in declining supplied something more significant, because what has been done to that one juror in the days since has put the logic this essay concerns on more naked display than any verdict could have.

The logic runs as follows: Sane, well-adjusted, normal people do not send their husbands on errands, take their children to the basement one by one, and strangle them with exercise bands. The act is so monstrous that no intact mind could have performed it. Therefore the mind that performed it was not intact, and therefore its owner is not guilty. I have heard this argument from thoughtful people, and I understand its pull; I wrote in an earlier essay that killing your own children is de facto evidence of mental instability, and I meant it. But follow the logic to its destination. If the monstrousness of the act is itself the proof of the madness that excuses it, then the crime can never be committed by a guilty person. Every mother who strangles her children is acquitted by the strangling. The worse the deed, the stronger the defense, and filicide becomes a crime that abolishes itself in the act of its commission. A legal category that functions this way is not legitimate. The center cannot hold.

Begin with what the insanity defense actually is. The definitive eight-state study found the defense raised in under 1 percent of felony cases and successful in about a quarter of those attempts, which works out to roughly one felony case in four hundred.⁴ More striking still, only 7 percent of the successes came from a jury; the rest were agreed dispositions, cases in which the state's own experts looked at a floridly psychotic defendant and did not contest the conclusion.⁵ The contested jury acquittal, the scenario everyone pictures, is the rare exception, which is why a case like Clancy's functions as a stress test of the doctrine rather than an ordinary application of it. Massachusetts stresses it further, because Massachusetts is nearly alone in how it allocates the burden of proof. Once a defendant produces any evidence of lack of criminal responsibility, the Commonwealth must prove her sanity beyond a reasonable doubt,⁶ and since 2016 the jury no longer even hears an instruction presuming sanity.⁷ More than thirty states put that burden on the defendant, and four have abolished the defense outright.⁸ Here the state must prove a negative, about a mind, to the highest standard the law knows, and the more incomprehensible the crime, the harder that burden becomes. Massachusetts law converts the atrocity itself into reasonable doubt. Proof by atrocity is not a rhetorical excess in this Commonwealth. It is very nearly the operating instruction.

Now consider what eleven of twelve jurors were prepared to certify, because the day itself was reconstructed in court from morning to night. It began with a pediatrician's appointment for her five-year-old, where the staff noticed nothing unusual about the mother; it continued with a snowman built with the two older children and photographs texted to her mother and husband, a day her husband would describe as one of her best.⁹ Then her phone takes over the narration.¹⁰ At 4:02 that afternoon she searched for a children's laxative. At 4:13 she searched for a Plymouth takeout restaurant and checked the driving time. At 4:48 she called the pharmacy to confirm the medicine was in stock, a call the store manager would testify to as a perfectly normal interaction with a clear and coherent customer. At 4:53 she texted her husband that she had not cooked anything, and at 5:10 she placed the dinner order that would send him out to fetch it. He stopped at the pharmacy at 5:32 and called her; she sounded quiet, and composed enough that he kept driving to the restaurant. He walked back into the house at 6:09 and called 911 two minutes later.¹¹ The insanity on offer is therefore an insanity that arrived sometime after she answered that 5:32 call in a voice that raised no alarm, and that finished its work before 6:09. It is a total eclipse of the moral faculty lasting at most thirty-seven minutes, in a woman whom five clinicians, a perinatal program, and a five-day psychiatric admission had never once observed to be psychotic before that half hour,¹²¹³ and whom the Commonwealth's examiner, after two days with her this spring, described in terms of rationality and order, not madness.¹⁴ It arrived punctually within the one window of opportunity she had herself constructed, errand by errand, and it departed with her husband's headlights in the driveway.

The jury also heard where her dark thoughts went, and where they did not. In the first days of January she told her husband about disturbing thoughts involving the children, which is part of how she came to McLean.¹⁵ She never told Dr. Jennifer Tufts, the psychiatrist who saw her by telehealth the day before the killings, heard her deny suicidal and homicidal thoughts once again, and testified that she would have been "very concerned" had she known what the husband knew.¹⁶ The prosecutor put the meaning of that asymmetry plainly in her closing: Clancy concealed the thoughts from her providers for fear the authorities would take her children, and "she knew that it was wrong, and she was able to conform her behavior to the law."¹⁷ I struggle to improve on that sentence. A person who sorts her confessions by audience, who tells the one listener who cannot commit her and hides the same thoughts from the mandated reporters who could, is performing continuous moral triage. She is weighing how a thought will be judged, by whom, and with what consequences, which is to say she is doing fluently the very thing the defense says she could not do at all: telling right from wrong and steering by the difference. She sent away the one person who would have stopped her, because she knew that what she was about to do was a thing he would stop. When he called mid-errand she gave him a voice worth not hurrying home for, because, as the prosecutor argued, she still had to finish.¹⁸ And when she woke in the hospital, among her first questions was whether she had a lawyer.¹⁹

Here I will stop citing for a moment and speak from my own chair, because I have spent a career in emergency departments and psychotics are among my daily company. Truly psychotic people generally cannot hide it from everyone. The delusional are obvious to everyone around them, which is why so many arrive in my department in the company of police. The hallucinating either suffer brief, intermittent intrusions that frighten them into seeking care, or they are so disorganized that the illness announces itself from across the room. What this defense proposes is a different creature entirely: a psychosis of intense, continuous command hallucinations and delusions of control, sustained across an afternoon of pediatric appointments, snowmen, and takeout logistics, invisible to the pediatrician's staff, invisible to her husband on the telephone, invisible in the photographs, having also been invisible, in the weeks before, to the five clinicians, the perinatal program, and the staff of one of the most prestigious psychiatric hospitals in the world. Its only sustained witness is the defendant herself, describing it afterward. Psychosis is typically not subtle, at least not the variety said to compel a mother to kill her children, and in my entire professional life I have never once encountered the presentation this defense requires. The toxicology then closes the circle with a detail that borders on satire. The drug most prevalent in her blood that evening was quetiapine, an antipsychotic she had spent her final weeks pushing to give up, which is to say the very class of medicine one would prescribe for the episode she describes, and the class that maintains her lucidity at Tewksbury today.²⁰²¹ What the defense calls causative then, her own doctors call therapeutic now.

I concede that I cannot know any of this for certain. Deception and psychosis are obviously not mutually exclusive, and depression can cause psychotic features. The forensic literature contains organized psychotics who planned carefully around their delusions, and the defense's answer is that a command hallucination can coexist with cunning. I do not take issue with this and have seen plenty of psychotic patients making bizarre plans to escape the objects of their paranoid delusions. But look at the shape of what the eleven accepted in the concrete: an illness invisible to every professional before, invisible to every professional after, undetectable on the telephone during, and confined with perfect punctuality to the only interval in which it could operate unopposed. In my opinion the most likely account of a woman who hid her thoughts from her doctors, cleared the house, kept it cleared, and woke asking for counsel is not that she was incapable of knowing wrong from right.

One more objection will arrive on schedule: but what was her motive? I have no idea, and it does not matter. Motive is not an element of murder. The Commonwealth must prove intent, not explanation, and the absence of a reason we can live with is not evidence of insanity. Notice what the demand for a motive actually is. It is this essay's opening logic: we cannot imagine why a mother would do this, therefore she must have been mad, therefore she is not guilty. Some acts will never yield a why that satisfies anyone. What the record supplies instead is sufficient: she planned the hour, she concealed the thoughts, she cleared the house of the one person who would have stopped her, and everything she did before and after says she knew that what she was doing was wrong. That is enough.

How, then, did eleven of twelve vote to acquit? Not, I think, because they were fools, but because Massachusetts asked them a question constructed to produce that answer. Once the defense was raised, the Commonwealth was required to prove this defendant's sanity beyond a reasonable doubt,²² which is to say it was required to prove, to the criminal law's most exacting standard, the contents of a mind, in a dead hour more than three years gone, with no living witness other than the woman whose liberty turns on the answer and who cannot be compelled to testify. No such proof exists or can exist. We cannot establish beyond reasonable doubt what was in anyone's head an hour ago, let alone in 2023, and so the law outsources the impossibility to psychiatry and calls it expertise. The jury duly watched two forensic examiners, equally credentialed, armed with the same records, reconstruct the same half hour of a stranger's mind and return opposite certainties in the same week.²³ I am a physician, and I will say plainly what that spectacle is: retrospective mind-reading, a séance with board certification, tarot performed in a courtroom because the law demands an answer that medicine cannot supply. Justice Frankfurter once mocked Oregon for making a defendant prove "beyond a reasonable doubt that, being incapable of committing murder, he has not committed murder."²⁴ Massachusetts runs the absurdity in reverse and calls it protection: the state must prove, beyond a reasonable doubt, that a mind it cannot enter was never in a place it cannot see. A burden like that is not a safeguard but a standing invitation, to the very inference this essay began with, that the deed was so terrible the doubt writes itself. Eleven jurors accepted it.

None of this is a law of nature. More than thirty states place the burden of proving insanity on the defendant who asserts it.²⁵ Congress, after the Hinckley acquittal, required federal defendants to prove insanity by clear and convincing evidence.²⁶ Oregon for decades demanded that the defendant prove insanity beyond a reasonable doubt, and the Supreme Court held that arrangement constitutional in Leland v. Oregon in 1952 and has never unsaid it.²⁷ In 2020 the Court went to the root of the matter: the Constitution does not oblige a state to maintain an insanity defense keyed to moral incapacity at all. Kansas folded the question into ordinary criminal intent, and Kahler v. Kansas blessed the choice, six votes to three.²⁸ The menu, in other words, is wide open, and Massachusetts has chosen the most credulous item on it. If we are to keep the plea at all, and I am no longer certain we should, the reform is a single sentence: the defendant who asserts that her mind was absent must prove it, clearly and convincingly at minimum, and Leland says we may demand it beyond reasonable doubt. Sanity is the background assumption behind every contract, consent form, vote, and marriage in the Commonwealth. It can be the background assumption of a murder trial. Had that sentence been law this summer, the question in the Clancy jury room would have worn its proper grammar: not whether the state had disproven an eclipse nobody witnessed, but whether the defense had proven one.

That is the argument I had drafted about the question the jury was asked. What no draft anticipated was what would be done to the juror who answered it. Begin inside the courtroom, where it began. On the Thursday, the forewoman's notes disclosed that a single juror stood apart from the eleven, and because the impasse was argued in open court, the public knew the holdout's sex before the trial was over.²⁹ The judge questioned jurors about the deadlock, a step so fraught that a veteran defense attorney watching from a distance called it "very dangerous" and worried the deliberative process had been broken.³⁰ On the Friday morning, Mr. Reddington asked Judge Sullivan to remove the man outright. He told the court the juror was refusing to apply the law, was "not being honest," and, he went so far as to say, "lied under oath."³¹³² When the judge declined to lean on the panel, counsel reviewed his performance for him: "You did it yesterday, you did it soft. You didn't do it forcefully."³³ Sullivan's answers deserve a record of their own, because they are what the system sounds like when it holds: "It's their duty to accept the law as I've given it to them." "I'm not going to do a further inquiry of this juror." And, to the demand for a firmer performance, "I'm not an actor. I'm just giving the instructions."³⁴ The law behind those answers is four decades old and directly on point. In Commonwealth v. Connor, the Supreme Judicial Court held that a deliberating juror may be discharged only for reasons personal to the juror and entirely unrelated to the case, and it warned, with something close to prophecy, that claims that a juror will not follow the law "may be mere euphemisms for the truth: that the juror was persistent in asserting a minority position." The court then added a sentence every republic should keep framed on a wall: "The possibility that an unreasonably stubborn or eccentric juror will be seated is an unavoidable risk of the jury system."³⁵ Denied at the trial court, the defense ran to the Supreme Judicial Court itself with an emergency petition, arguing in substance that a deliberating juror was breaking the law by the way he was voting. A single justice heard it for roughly fifteen minutes and denied it, and the mistrial became final that afternoon.³⁶

Then the campaign left the building. At his press conference, counsel for the defendant thanked the jurors, "minus one." He announced the split: "It was 11-1 for an acquittal, and one individual who recognized that there was reasonable doubt and refused to apply the law." He told the cameras that the eleven "know that they were robbed by one man for whatever his agenda was, who stole seven weeks of the life of these other jurors." And he closed with a benediction: "I hope that guy can sleep well at night."³⁷ Take the two halves of that performance separately. The first is the disclosure. The number, eleven to one, and the sex of the one are things the public was never supposed to possess. The Supreme Court held a century ago, in Brasfield, that a trial judge may not even ask a deadlocked jury how it divides, because the mere asking tends to coerce,³⁸ and the deliberation room is wrapped in silence for the same reason: a juror who knows his arithmetic will be published does not deliberate for his oath, he deliberates for the audience. That protection was stripped from this jury by an officer of the court in time for the evening news, with a retrial looming in the same county, in front of the very population from which the next twelve will be drawn. The second half is the targeting. "His agenda." "That guy." A famous case, a known county, a disclosed sex, a national audience, and within days a national magazine was publishing speculation about the inside of this man's head.³⁹ He now stands one leaked name away from the #MeToo treatment, the doorstep cameras, the archived address, the discovered employer, and everyone who has watched the internet work knows it. Lawyers moving to remove a holdout is nothing new; Connor exists because they try. What I cannot find is a precedent for a defense attorney prosecuting a juror at a press conference for the crime of an unwanted vote, and I am content for that search to fail, because a bar that normalizes the practice will have repealed the jury in everything but name. This country keeps exactly one sacred juror in its imagination, the lone holdout of Twelve Angry Men, celebrated in every civics classroom for standing against eleven. The reverence turns out to be conditional. Hold out against guilt and you are the conscience of the republic. Hold out against an acquittal and you are "that guy," with an "agenda," who deserves to lose sleep.

There is an old answer to all of this, and it turns three hundred fifty-six years old this autumn. In 1670 a London jury refused to convict William Penn and William Mead for preaching to an unlawful assembly. The court locked the jurors up without food, drink, fire, or tobacco to help them reconsider, and when they would not, it fined them and jailed the ones who refused to pay. Penn called out to the panel to mind their privilege; the foreman, Edward Bushel, answered that they never would give it away, and from his cell he sued out the writ that made the answer permanent. Chief Justice Vaughan's ruling in Bushel's Case, that no juror may be punished for his verdict, has been the foundation stone of every honest jury seated since.⁴⁰ It is also, allowing for a change of instruments, a description of last week. We no longer starve holdouts; we hand them to the news cycle. The one thing the public record shows this juror actually did is the thing the court's own charge commanded, in words Massachusetts has required since 1973: do not surrender your honest conviction as to the weight or effect of the evidence solely because of the opinion of your fellow jurors, or for the mere purpose of returning a verdict.⁴¹ He may be wrong about Lindsay Clancy. Eleven apparently conscientious people concluded that he was, as have millions of the online commentariat. But being wrong in good faith is his privilege, in Penn's exact sense of the word, and a juror who holds an honest conviction under that instruction owes nobody an apology, least of all the lawyer whose case failed to move him. The Supreme Court reminded everyone in Ramos v. Louisiana that unanimity extracted by intimidation is not unanimity at all.⁴²

And what was the verdict the eleven stood ready to return? Look at what an acquittal purchases, because the public imagines that "not guilty by reason of insanity" means a locked ward forever, and in Massachusetts it means nothing of the kind. The acquittee is held for observation for 40 days and then, if so ordered, committed for six months; after that the commitment must be renewed every single year, and at every renewal the Commonwealth must prove, again beyond a reasonable doubt, that she remains mentally ill and dangerous.⁴³⁴⁴ The first year the state cannot carry that burden, she is entitled to release. Not eligible. Entitled. A 2015 investigation found that 77 percent of the men committed to Bridgewater State Hospital after insanity acquittals since 2004 had already been released, that 85 percent of acquittees committed to Department of Mental Health facilities had returned to the community, and that they walked out with voluntary treatment plans and no guaranteed supervision at all.⁴⁵ Among them was Angela Vasquez, found not criminally responsible for killing her two children, ages ten and thirteen, and released over the objection of the district attorney.⁴⁶ Massachusetts has already run the Clancy experiment, and everyone arguing about this case as though the question were prison versus permanent asylum should know how the experiment came out. The real choice on the table is prison versus a renewable annual subscription to confinement that the state must re-justify, forever, to the criminal law's most demanding standard, against a patient who will be, by then, medicated, stabilized, remorseful, and represented. Moreover her defense is not that she remains insane now, but that she was temporarily insane on one particular day three years ago. If she is found not guilty by reason of insanity, the official account of that insanity will be that it is already over with. Those who are hopeful that this account will result in lifelong confinement should not hold their breath.

Fairness requires the other side of the ledger, so here it is. Nationally, insanity acquittees are often confined as long as or longer than they would have served in prison; the classic study found that offense severity, not clinical condition, predicts how long acquittees stay in, which tells you the hospitals are quietly running sentences,⁴⁷ and a recent review collects the numbers: average confinements of five to seven years, hundreds of acquittees held more than fifteen years, and a Supreme Court case blessing the confinement of a man for eight years on a charge that carried a one-year maximum.⁴⁸ Andrea Yates, the standard against whom every filicide defendant is measured, has now spent two decades in Texas state hospitals, though this is not enforced on her but because she repeatedly waives her own annual release reviews.⁴⁹ Where states actually supervise released acquittees, the results are reasonable: Oregon's conditional-release board produced new-felony revocation rates in the low single digits.⁵⁰⁵¹ I concede all of it, and notice what the concession amounts to. The system is not uniformly lenient; much worse, it is arbitrary. One acquittee serves shadow decades for a minor charge; another walks out of Bridgewater into nothing. The outcome is unhinged from culpability, which the verdict already excused, and only loosely hinged to dangerousness, which is relitigated annually until the state loses once. It is a lottery in which the prize is drawn every year, and the ticket was purchased with an atrocity.

Then there is the question of who wins the lottery, and here the data are uncomfortable in a direction the commentary prefers not to examine. Mothers who kill their children fare differently from fathers who do. A study of filicide outcomes in Austria and Finland found mothers received murder convictions and life sentences less often than fathers.⁵² An analysis of 298 Canadian filicide cases found mothers less likely to be convicted, less likely to be imprisoned, and sentenced more briefly when they were, a gap the authors attribute to social expectations and the medicalization of maternal violence.⁵³ American research finds the sorting begins before any verdict: decision-makers typify women defendants as mad and route them toward psychiatric evaluation, while typifying Black defendants as bad and routing them toward punishment.⁵⁴ The case names make the pattern vivid. Yates, acquitted. Deanna Laney, who stoned two sons to death, acquitted and released to outpatient life after eight years.⁵⁵ Dena Schlosser, acquitted, released within two years, recommitted, and later discovered working at a Walmart under another name.⁵⁶⁵⁷ Otty Sanchez, acquitted.⁵⁸ Against them: Chris Watts, who did not even attempt the defense because no one would have entertained it.⁵⁹ John Jonchuck, who dropped his five-year-old daughter off a bridge amid florid psychosis, jury verdict guilty, life.⁶⁰ Timothy Ray Jones Jr., five children, a schizophrenia defense, death sentence.⁶¹ The tenderness is not distributed by diagnosis. During this trial a popular legal commentator posted that she desperately wanted to give Lindsay Clancy a hug.⁶² No one has ever proposed hugging Chris Watts, and the difference between those two impulses is not psychiatric. Honesty compels the complication: Carol Coronado, a mother who stabbed her three daughters, was convicted and sentenced to life without parole,⁶³ so the pattern is a tendency and not a law. But it is a strong tendency, and a doctrine administered by sympathy will distribute its mercy the way sympathy always has. Eleven to one is what that tendency looks like in a jury room.

On race the honest report is that rigorous modern data barely exist. What can be documented is the sorting at the evaluation stage,⁶⁴ and a recent study finding no racial difference in competency determinations once defendants were referred, though Black defendants were referred for additional testing at three times the rate.⁶⁵ What can also be documented is the revolving door: Decarlos Brown Jr., schizophrenic, arrested roughly fourteen times, released in January 2025 on a written promise to appear, his court-ordered psychiatric evaluation still pending six months later when he drove a knife into Iryna Zarutska's neck on a Charlotte train.⁶⁶⁶⁷ Brown's track is competency, not acquittal; a federal judge found him incompetent to stand trial this June, and he sits in restoration treatment, triable perhaps someday.⁶⁸ But the through-line to this case is exact. The system could not hold Brown before a killing, because his liberty was sacred and his illness was nobody's business. Clancy’s defenders criticize this same system for not involuntarily holding her before she committed the murders, even though she had no documented evidence in any medical record to support such an action (and I strongly suspect that, had she been involuntarily hospitalized anyway, the same critics would have instead complained about the unjust kidnapping and imprisonment of a depressed but harmless young mother). The same system is now asked to hold Lindsay Clancy after one, one year at a time, forever. It failed the test in the easy direction. There is no reason to expect it to pass in the hard one.

Other countries at least do their mercy honestly. England's Infanticide Act, on the books since 1938, provides that a mother who kills her child within twelve months of birth, while the balance of her mind is disturbed by childbirth's effects, is punished as for manslaughter rather than murder, and some two dozen countries have versions of the same statute.⁶⁹⁷⁰ I think the law is wrong, and its arbitrariness is famous even among its admirers; a psychotic mother who kills her thirteen-month-old falls outside it while a mother who batters her eleven-month-old falls within, and Andrea Yates herself would not have qualified.⁷¹ But observe its one great virtue: it is a law. A legislature debated the proposition that maternal child-killing deserves categorical leniency, voted for it, and owns it. The American method reaches the same destination through the back door, case by case, jury by jury, expert by hired expert, with the leniency laundered through diagnosis so that no one ever has to defend it as policy. We have the English rule without the English honesty, administered by sentiment instead of statute, and the laundering is why every trial like this one becomes a referendum on psychiatry instead of a question about justice.

So let me state the two coherent positions, because everything else on offer is incoherence managed by annual hearing. Either Lindsay Clancy was criminally responsible for strangling Cora, Dawson, and Callan, in which case the sentence is life imprisonment and the argument ends. Or she truly was not, her mind so broken that the acts were not hers, in which case the state owes her treatment and owes everyone else her custody, in an institution, for as long as an illness capable of producing three dead children could possibly persist, which is to say indefinitely, with the burden of proving recovery resting on her and not on a Commonwealth that must re-win the case every year until it loses once. Prison or asylum, chosen once, honestly, for good. What is indefensible is the system we actually have, the one the public discovered watching this trial: acquittal by atrocity, commitment by the year, release by attrition, a Vasquez every decade, and a fresh set of doctors put on trial each time to explain why they did not prevent what the law forbade them to prevent.⁷²⁷³

So the case returns to the machinery. A status conference is set for the end of September; the district attorney, who calls the charges warranted, will decide whether the Commonwealth tries her again; she waits at Tewksbury State Hospital either way, medicated and, by every account entered into evidence, lucid.⁷⁴⁷⁵ The defense speaks of a federal double-jeopardy challenge, and it will discover what Blueford v. Arkansas already settled: a foreperson's tally from a jury that has not finished lacks the finality of an acquittal, and a hung jury has never barred a retrial.⁷⁶ Eleven votes are not a verdict. That arithmetic is the whole of the jury right, and it protects Lindsay Clancy exactly as it protects the Commonwealth, a symmetry her counsel understood perfectly on every day of his career until the eleven happened to lean his way. If there is a second trial, twelve new citizens of Plymouth County will file into the same box who will at that point know, as this jury could not, exactly what happened to the last man who said no. That knowledge is the campaign's true legacy, and it should trouble people who will never think about this case again. In 1670 the price of an honest verdict was a cold cell, and the law answered that no juror may be punished for his conscience. In 2026 the price is a press conference and whatever the internet decides to do next, and the law has not yet answered. Until it does, the answer lives where it lived in Bushel's day, in the nerve of one ordinary citizen at a time. The act cannot be its own acquittal, the atrocity cannot be its own proof, and eleven votes, however sincere, cannot be a verdict. For the moment, one man's conscience is all that stands between this Commonwealth and those propositions, and I decline to join the crowd punishing him for it.

This essay is part of a series on the trial of Lindsay Clancy. Read the other parts below:
Part 1 - This Is a Murder Trial, Doctor
Part 2 - The Pharmacological Alibi

1. WBUR News. Judge declares mistrial in Clancy case after jurors, with "heavy heart," fail to reach verdict. September 4, 2026. https://www.wbur.org/news/2026/09/04/lindsay-clancy-murder-trial-verdict-massachusetts

2. CBS News Boston. Lindsay Clancy murder case ends in mistrial after her attorney's last-ditch attempt to avoid jury deadlock. September 4, 2026. https://www.cbsnews.com/boston/live-updates/lindsay-clancy-murder-trial-hung-jury-mistrial-verdict-watch-live-updates/

3. Boston 25 News. Reddington calls out apparent holdout juror after Clancy mistrial. September 2026. https://www.boston25news.com/news/local/reddington-calls-out-apparent-holdout-juror-after-clancy-mistrial/ZR664PYGNBH47B3CXULNIQ7A5M/

4. Callahan LA, Steadman HJ, McGreevy MA, Robbins PC. The volume and characteristics of insanity defense pleas: an eight-state study. Bull Am Acad Psychiatry Law. 1991;19(4):331-338. https://jaapl.org/content/jaapl/19/4/331.full.pdf

5. Callahan LA, Steadman HJ, McGreevy MA, Robbins PC. The volume and characteristics of insanity defense pleas: an eight-state study. Bull Am Acad Psychiatry Law. 1991;19(4):331-338. https://jaapl.org/content/jaapl/19/4/331.full.pdf

6. Commonwealth v. Keita, 429 Mass. 843 (1999). https://law.justia.com/cases/massachusetts/supreme-court/volumes/429/429mass843.html

7. Sultan B. Commonwealth v. Lawson and Commonwealth v. Griffin: recent changes in criminal responsibility and the presumption of sanity. Boston Bar Journal. 2017. https://bostonbar.org/journal/commonwealth-v-lawson-and-commonwealth-v-griffin-recent-changes-in-criminal-responsibility-and-the-presumption-of-sanity/

8. FindLaw. The insanity defense among the states. https://www.findlaw.com/criminal/criminal-procedure/the-insanity-defense-among-the-states.html

9. AOL News. Massachusetts mom was having "one of her best days" before she allegedly strangled 3 children, husband told police. 2023. https://www.aol.com/news/massachusetts-mom-having-one-her-012259593.html

10. Oxygen. Lindsay Clancy trial timeline: her and Patrick Clancy's day before the kids were killed. August 2026. https://www.oxygen.com/crime-news/lindsay-clancy-trial-timeline-her-patrick-clancys-day-before-kids-killed

11. Oxygen. Lindsay Clancy trial timeline: her and Patrick Clancy's day before the kids were killed. August 2026. https://www.oxygen.com/crime-news/lindsay-clancy-trial-timeline-her-patrick-clancys-day-before-kids-killed

12. Los Angeles Magazine. Two Lindsay Clancy providers, two crucial accounts of her mental state before the killings. August 2026. https://lamag.com/crimeinla/two-lindsay-clancy-providers-two-crucial-accounts-of-her-mental-state-before-the-killings/

13. Galt J. The Pharmacological Alibi. Factory Rounds. August 24, 2026. https://substack.galtmd.com/p/the-pharmacological-alibi

14. East Idaho News. Live updates: psychiatrists offer dueling testimonies of Lindsay Clancy's state of mind when killing her children, on Day 18 of trial. August 21, 2026. https://www.eastidahonews.com/2026/08/live-updates-psychiatrists-offer-dueling-testimonies-of-lindsay-clancys-state-of-mind-when-killing-her-children-on-day-18-of-trial/

15. Los Angeles Magazine. Two Lindsay Clancy providers, two crucial accounts of her mental state before the killings. August 2026. https://lamag.com/crimeinla/two-lindsay-clancy-providers-two-crucial-accounts-of-her-mental-state-before-the-killings/

16. Los Angeles Magazine. Two Lindsay Clancy providers, two crucial accounts of her mental state before the killings. August 2026. https://lamag.com/crimeinla/two-lindsay-clancy-providers-two-crucial-accounts-of-her-mental-state-before-the-killings/

17. The Boston Globe. Lindsay Clancy trial live updates: closing arguments. August 27, 2026. https://www.bostonglobe.com/2026/08/27/metro/lindsay-clancy-trial-live-updates/

18. The Boston Globe. Lindsay Clancy trial live updates: closing arguments. August 27, 2026. https://www.bostonglobe.com/2026/08/27/metro/lindsay-clancy-trial-live-updates/

19. The Boston Globe. Lindsay Clancy trial live updates: closing arguments. August 27, 2026. https://www.bostonglobe.com/2026/08/27/metro/lindsay-clancy-trial-live-updates/

20. Charalambous P, et al. Lindsay Clancy trial: toxicology expert testifies that drug levels were low. ABC News. August 2026. https://abcnews.com/GMA/News/lindsay-clancy-trial-toxicology-expert-testifies-drug-levels/story?id=135394092

21. Galt J. The Pharmacological Alibi. Factory Rounds. August 24, 2026. https://substack.galtmd.com/p/the-pharmacological-alibi

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