The Insanity Debate Changes at the State Line

In the News

Fox News reports that the trial of Lindsay Clancy, the Massachusetts mother accused of killing her three children, has become a social media obsession, with millions arguing whether postpartum psychosis excuses what she did. Boston defense attorney Peter Elikann named the problem: “everybody’s an expert.”Old,Fashioned,Jury,Box,With,Twelve,Matching,Armchairs

Here’s Our Take

Nearly all the commentary assumes the question has one answer, regardless of the state. Clancy’s jurors are applying a Massachusetts rule that asks whether she could appreciate the wrongfulness of her conduct. Utah abandoned that question in 1983. Under Utah Code § 76-2-305, a mental condition negates guilt at trial only when it means the defendant “lacked the mental state required as an element of the offense charged”—in this case, whether she acted knowingly or intentionally. Clancy’s defense concedes she intended the deaths, so a Utah jury would convict on three counts of aggravated murder, most likely with a finding of “guilty with a mental condition.” That finding reduces neither the offense nor the sentence. Her psychosis becomes primarily relevant after conviction, when under § 77-16a-104 the court decides whether she serves that sentence in prison, on probation, or at the state hospital.

A Utah jury still decides the facts of mental state, but not the older free-standing question of whether someone who cannot appreciate wrongfulness should be excused. Utah made that policy choice in advance and channels each case through that stricter standard.

Closing

If this happened in Utah, the debate would not be whether a psychotic parent could “walk free.” It would be whether the state’s narrower rule—taking that question away from a jury of peers—best balances moral blame, public safety, and the limits of criminal punishment. Libertas is not running a bill. Utahns should know which rule they live under, and what that choice costs.

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About the author

Josh Nemeth

Josh Nemeth is the Criminal Justice Policy Analyst at Libertas Institute. Before joining Libertas, he spent a decade in criminal prosecution between Utah and Montana, most recently as a Special Victims Unit prosecutor for Cache County. He also works as a criminal defense attorney, giving him experience on both sides of Utah’s criminal justice system. That background informs his commitment to criminal justice reform grounded in limited government and individual liberty, with practical solutions that protect public safety. Josh holds a J.D. from BYU’s J. Reuben Clark Law School and degrees in business. A father of four, he lives in rural Cache County with his wife and children.

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