More on Andre Thomas, Insanity Defense

The case of Texas death row inmate Andre Thomas has prompted a great deal of discussion about the insanity defense and about whether the death penalty is an appropriate punishment for offenders with severe mental illness.

Here's an article that appeared Sunday in the Dallas Morning News ("Case Fuels Texas Debate on Insanity Defense," April 12, 2009):

Everyone agrees Andre Thomas is crazy.

In 2004, he cut out the hearts of his wife and her two children and pocketed them. Before his murder trial, he plucked out his right eye. In January, while on death row, he ripped out his other eye and swallowed it.

Thus far, courts say Thomas is not insane.

His case is a classic example of the complexities of Texas' insanity defense law - and why some mental health advocates are pushing to change it. Several bills pending in the Texas Legislature would do just that.

With medication and treatment, Thomas eventually was found mentally competent to stand trial, because he could communicate and assist his attorney in his defense. At trial, he was found to be sane at the time of the crime because he knew the difference between right and wrong. And he may be found competent to be executed if he understands what execution means and why he is being killed.

Thomas is "clearly 'crazy,' " a judge on the Texas Court of Criminal Appeals wrote in a concurring denial of his appeal last month, "but he is also 'sane' under Texas law."

Death penalty opponent Maurie Levin, an adjunct professor at the University of Texas School of Law, is appalled. "There is something just horribly wrong with a system that permits somebody as severely mentally ill as Andre Thomas to be found competent to stand trial or sane at the time of that crime," said Levin, who consulted with Thomas' defense attorney.

"We need to change the law," said Brian Shannon, a Texas Tech law professor, because a mentally ill person may know their conduct is wrong but be unable to fully comprehend the situation because the illness affects his "emotional state and thinking and reasoning ability."

Some defendants, such as Thomas, know killing is wrong but say God is telling them to do it.

Proposed legislation

Shannon supports bills pending in the Legislature to broaden the law, in all cases, not just capital cases, to say that a defendant must "appreciate," not just "know," the difference between right and wrong and that the wrong should be a moral one, not just legal.

Such changes, which have been proposed in past sessions, would bring Texas closer to the federal standard on insanity. Supporters are hopeful for passage this time, but for now, the Texas law is similar to that in other states.

"Texas is right within the norm," said Bruce Winick, who teaches law at the University of Miami, and psychiatry and behavioral sciences at the medical school. "People aren't going to say, 'Oh, there goes Texas again.' "

Texas, like many states, narrowed the insanity defense in the 1980s amid outrage over John Hinckley's acquittal in the attempted assassination of President Ronald Reagan. Hinckley has been confined to a mental hospital since 1982.

Shannon said Texas law also should change to inform jurors what happens to defendants found not guilty by reason of insanity. They do not "just walk free," he said.

A bill authored by Rep. Senfronia Thompson, D-Houston, would allow jurors to be told that such defendants are sent to a mental hospital if acquitted. Long-term hospitalization is not guaranteed, but "even if someone gets well and is discharged, there's still oversight by the court," Shannon said.

Prosecutors oppose efforts to broaden the not guilty by reason of insanity defense.

"The people who are truly mentally ill, to the degree that their functioning is impaired, I think they are protected by the existing system," said Karla Hackett, who handled the Thomas appeal for Grayson County.

Thomas' attorneys had numerous opportunities to explain the effect of his mental illness to jurors. In the weeks before the murders, Thomas heard voices, behaved strangely and left mental facilities without treatment.

But jurors also heard how he planned the crime, intentionally avoided detection, then turned himself in to authorities. Prosecutors said drinking and drug use also contributed to his psychotic episodes.

"There's no doubt he has mental illness," Hackett said, but " why does he have mental illness?" Under Texas law if the illness is caused or worsened by "voluntary intoxication" such as drug or alcohol abuse, "you don't get to claim insanity."

Levin said the prosecution is implying that "if he hadn't been intoxicated, he wasn't crazy, he was faking. I think Andre's actions since the crime - including gouging out his eye pretrial and taking out a remaining eye three months ago - have proven them wrong."

Jurors weigh in

Jurors heard experts from both sides, but didn't buy the argument that Thomas' mental illness meant he shouldn't be held criminally accountable, Hackett said.

Thomas' appellate attorneys, who declined to comment, claim his trial counsel was ineffective. Appellate courts have disagreed and deferred to the jury's judgment.

"What angers people is when they don't know the whole case," Hackett said. "It's, 'Oh, my gosh, he's got no eyeball, I can't believe they're doing this, he must be crazy.' Well, don't say that until you've been there, until you've sat in the jury box for six weeks."

Hackett said changing the wording of the law would "open up a whole new area of litigation. Now we're going to argue, what does the word appreciate mean? Whose morals?"

Williamson County District Attorney John Bradley said the current law "strikes the appropriate balance."

Informing jurors about what happens if the defendant is found not guilty by reason of insanity would make the process less objective, Bradley said. He thinks jurors might speculate about what could happen and be "frightened into convicting the defendant" if they understood the limits of judicial oversight when a defendant is found not guilty by reason of insanity.

High court ruling?

Winick, the University of Miami instructor, expects the U.S. Supreme Court eventually to weigh in on the issue. So far, the court has ruled only that an inmate must be competent to be executed. Last summer the high court also ruled a mentally ill defendant cannot represent himself in court.

But the court has not ruled on whether an inmate may be forcibly medicated to render him competent - and therefore eligible for execution. That issue may be ripe for the Supreme Court to decide.

Winick thinks the court ultimately may have to rule whether it is unconstitutional to impose the death penalty on someone who is sane but mentally ill. That issue is a "natural extension," he said, of the court's decisions prohibiting execution for the mentally retarded and juveniles because they have less ability to understand the consequences of their crimes.

Ron Honberg, director of policy and legal affairs for the National Alliance on Mental Illness, said it probably would be years before the issue reaches the court. The decisions regarding mental retardation and juveniles relied heavily on the fact that more than half of the states had abolished the death penalty for those individuals. So far, only a handful of states are even considering a
ban on executing the mentally ill. Texas is not among them.

- - - - -
DETERMINING INSANITY

Under current state law, mentally ill defendants undergo tests of mental competence at several stages:

1. Before trial: Defendants must be able to understand the trial process and be able to communicate with their attorney and understand the proceedings. A judge may make the determination at an examining trial where the defendant is represented by an attorney and may present evidence from experts. The defendant may request a jury decision.

2. At the time of the crime: If the defendant claims at trial to be not guilty by reason of insanity, he must prove he did not know his conduct was wrong while committing the crime. As in any criminal trial, he may request a judge or a jury.

3. At the time of execution: If the case results in a death penalty, an inmate cannot be executed if he does not understand what it means to be executed and why he is being put to death. If a claim of incompetence is made, a judge must hold a hearing to determine competency. Lower courts differ on whether an inmate may be forcibly medicated to achieve competency, which makes him
eligible for execution. The U.S. Supreme Court has not ruled on forcible medication.

- - - - -

Editor's Note: A district judge has ordered the forced medication of Texas death row inmate Steven Staley. Staley suffers from severe paranoid schizophrenia and has been hospitalized up to 19 times while on death row. He often has refused to take his medication because he thinks he is being poisoned.

In September 2007, the Texas Court of Criminal Appeals refused to hear Staley's appeal, ruling that the trial court's order was not "an appealable order" and that it would not consider overturning it.

More information on his case is available here and here.

Texas Mother to Remain in State Mental Hospital

Below is an update on the case of Deanna Laney, from the Tyler Morning Telegraph ("Woman Who Stoned Children to Death Will Remain in Mental Facility," July 8, 2008). Ms. Laney was found not guilty by reason of insanity for the murder of her children. She has spent the last four years in state mental hospitals.


The Texas Code of Criminal Procedure "prohibits the court and attorneys from informing a juror or prospective juror of the consequences to the defendant if a verdict of not guilty by reason of insanity is returned. The purpose of this provision is to prevent the jurors, if possible, from being influenced by the consequences of their decision to the defendant. It has been held that this provision does not deny fundamental fairnessto the defendant." (Texas Criminal Procedure and the Offender with Mental Illness: An Analysis and Guide, pp. 156-157).

Here's the article in full:

"Deanna Laney — who was found not guilty by reason of insanity after she stoned her young sons to death in 2003 — will remain in a mental facility for another year, a state district judge decided Monday.

A closed-door civil commitment hearing was held in 114th District Judge Cynthia Stevens Kent’s court, as it has been each year since Ms. Laney’s April 2004 capital murder trial.

After the hearing, defense attorney F.R. “Buck” Files Jr. said Judge Kent maintained the same order as she did last year.

When Ms. Laney was acquitted by a Smith County jury in April 2004, Judge Kent ordered Ms. Laney be placed in a maximum-security inpatient treatment facility. Since then, Judge Kent has presided over private hearings each year and determined that Ms. Laney should remain at an inpatient facility.
Last year, after attorneys discovered that Ms. Laney had been transferred from Vernon State Hospital to the Kerrville State Hospital and was being allowed unsupervised furloughs by doctors, Judge Kent put a stop to it at the request of prosecutors. Ms. Laney’s defense attorneys appealed her decision, but the 12th Court of Appeals ruled in April 2007 that the Texas Department of Mental Health and Mental Retardation could not grant Ms. Laney passes to leave the facility with her parents to go shopping and dining in the Hill Country.

In June 2004, Vernon State Hospital transferred Ms. Laney from its maximum-security facility to Kerrville State Hospital, a non-secure impatient facility, court documents state.

Between August and December 2005, Ms. Laney’s treatment team granted her brief passes off the hospital campus in Kerrville.

THE MURDERS

A jury found Ms. Laney, a 43-year-old housewife who home-schooled her children, not guilty by reason of insanity for stoning her sons to death on Mother’s Day weekend in 2003.

Joshua, 8, and Luke, 6, were found dead in the front yard of the family’s New Chapel Hill home, and then-14-month-old Aaron was found seriously injured in his crib.

Ms. Laney’s attorneys admitted during the trial that she had stoned her children, but contended that she was insane and did not know that what she was doing was wrong. Ms. Laney told authorities God told her to kill her children.

Under Texas law, people are found legally insane if, at the time of an offense, they did not know their conduct was wrong because of some mental illness or defect.

Ms. Laney was defended in trial by attorneys Files, Tonda Curry and LaJuanda Lacy, while Smith County District Attorney Matt Bingham, former First Assistant DA Brett Harrison and current First Assistant DA April Sikes prosecuted the case.

Judge Kent issued a restrictive and protective order, limiting what attorneys can say about the case."

Harris County Jury Rejects Death Penalty for Quintero

The Harris County jury that rejected Juan Quintero's insanity defense and found him guilty of capital murder in the death of Officer Rodney Johnson has sentenced him to life in prison without the possibility of parole. Some jurors cited the mitigating evidence presented by Quintero's defense attorneys in explaining their decision to spare his life.

Here are excerpts from an article that appears today in the Houston Chronicle ("Quintero's life sentence shocks victim's family," May 21, 2008):

"One juror said Juan Leonardo Quintero's life still has value.

Another said a convicted cop killer, even one in the country illegally, deserves mercy.

Neither sentiment offered much consolation to family members of murdered Houston police officer Rodney Johnson, who were stunned Tuesday when a jury spared Quintero and sent him to prison for life with no chance of parole.

Asked by state District Judge Joan Campbell if he had anything to say before he was sentenced, the 34-year-old Quintero replied, 'I'm sorry.'

Johnson arrested the landscaper from Mexico during a Sept. 21, 2006, traffic stop. The 12-year police veteran didn't notice Quintero was hiding a gun, which, while handcuffed in the patrol car's back seat, he used to shoot Johnson seven times.

Quintero's lawyers had argued unsuccessfully that he was criminally insane and incapable of knowing his actions were wrong.

'I believe he has value,' said juror Letty Burkholder, of Houston. 'He's loved by many of his family and friends, and that was number one. I felt like he has potential.'

The decision shocked Johnson's family. His sister collapsed in the lobby of the Harris County Criminal Justice Center, his mother-in-law shouted in the street. Johnson's widow sobbed in disbelief.

'My husband's life meant nothing — that's what I felt,' said Joslyn Johnson, also an HPD officer.

'If any case ever warranted the death penalty, this certainly did," she said. "The city lost a hero. I lost my husband.'

In front of the courthouse, her mother blasted the jury's decision.

'We wanted the death penalty,' Lorraine Crawford said. 'He's not sorry. He would do it again.'

'Not a life without value'

The decision came in the second day of deliberations for the jury, which convicted Quintero of capital murder on May 8. His defense team praised jurors for careful consideration of 'all of the evidence.'

'This is not a life without value,' defense attorney Danalynn Recer said later. She also said a life sentence would help both families because it ends the case, rather than subjecting them to years of appeals.

She said Quintero's remorse, mental health and family relationships were mitigating factors with jurors, who discussed the case with her afterward.

Assistant District Attorney Denise Bradley called it a sad day for law officers.

Speaking outside the courthouse, Bradley said she was disappointed with the verdict but respected it.

'We take solace in the fact that Mr. Quintero will spend the rest of his life behind bars,' fellow prosecutor John Jordan said.

Most of the jurors chose not to comment. One of two who spoke to reporters agreed that Quintero deserves to live. She said there were sufficient mitigating circumstances to opt for life in prison.

'I still feel we came to the right decision,' said Tiffany Moore, a 38-year-old marketing director from Houston. 'We could never bring Rodney back. I feel very sad for the family, losing a loved one.'

She said she wept while Rodney Johnson's sister, Susan Johnson, read a victim impact statement after the verdict.

'You are a murderer, plain and simple,' Johnson told Quintero while staring at him. She also belittled the defense team, accusing them of manipulating the system, especially with the insanity defense.

She later collapsed on the floor in tears as the family left the courthouse.

The officer's brother, David Johnson, wanted to see Quintero sentenced to death.

'He shot him four times in the back, three times in the head,' Johnson said. 'I can't believe that.
What's mitigation?'..."
***
Additional coverage by the Houston Chronicle is available here. Earlier posts on the case are available here, here, and here.

Mother with Mental Illness Pleads Guilty

According to the Tyler Morning Telegraph, Catherine Alana Stevens, a woman with a long history of mental illness, has plead guilty to murdering her 2-year-old son, William. ("Stevens Found Guilty Of Son’s Murder," May 10, 2008) Charged with capital murder, Stevens faced the death penalty at one point. With her plea agreement, she was given a life sentence and will be eligible for parole after serving 30 years. Unlike at least five other recent cases involving mothers with mental illness who have killed their children, Stevens will not receive mental health services or be committed to a state mental hospital.

Here are excerpts from the article:

"Smith County District Attorney Matt Bingham requested that her capital murder indictment be dismissed because of the plea agreement and 7th District Judge Kerry Russell granted it after he sentenced the defendant.

'We are very pleased with the resolution to this case through the hard work of the Tyler Police Department and First Assistant District Attorney April Sikes,' Bingham said. 'We were able to show that in fact (Mrs. Stevens) was not insane.'

Defense attorneys Brett Harrison and Tonda Curry had earlier filed a notice of intent to raise the insanity defense in her capital murder trial but withdrew the motion during the hearing. They said Mrs. Stevens was examined Friday by a doctor who found her competent to proceed with the guilty plea.

'In this case, this mother who killed her child will not be going to a state hospital,' Bingham said. 'She will be going to the penitentiary for life and will not be eligible for parole for 30 years, ensuring that she spends virtually the rest of her life in the penitentiary without a trial and having waived all rights to appeal.'

Bingham said there was no question that Mrs. Stevens had a lengthy history of mental illness, but it did not equate to legal insanity.

'Our (mental health) experts found on the night in question that she knew her conduct was wrong,'he said.

Harrison said the case was a terrible tragedy. He said all of the mental health experts, hired by the state and defense, agreed she had a long history of severe mental disease; but, under Texas law, that alone is not sufficient to establish the insanity defense. Because of that, Mrs. Stevens chose to plead guilty.

'This was fully her decision and we support her decision,' Harrison said.

Under Texas law, people are found legally insane if, at the time of an offense, they did not know their conduct was wrong because of some mental illness or defect.

Mrs. Stevens, clad in a tan jail jumpsuit and shackles, told the judge that over the last five years she had been confined several times in the Rusk State Hospital, a couple of times at the Behavioral Health Center and once at a Dallas hospital. She said she was treated for depression with psychosis.
Harrison said she was found competent to stand trial by several doctors early on in the case, but was examined again Friday before the guilty plea. ..."

and

"Mrs. Stevens was not the first woman to raise the insanity defense in her capital murder case in Smith County.

In 2004, Deanna Laney was found not guilty by reason of insanity by a Smith County jury after she stoned two of her young sons to death and critically injured her toddler in 2003.

After Ms. Laney was acquitted, 114th District Judge Cynthia Stevens Kent ordered her to be placed in a maximum-security inpatient treatment facility. Since then, Judge Kent has presided over closed-door civil commitment hearings each year and determined that Ms. Laney should remain at an inpatient facility."

Quintero Found Guilty

A Harris County jury has found Juan Leonardo Quintero guilty of capital murder in the death of Houston Police Officer Rodney Johnson ("Quintero convicted of capital murder in death of HPD officer," May 8, 2008). The case now moves to the sentencing phase, where jurors will decided whether to sentence Quintero to life in prison without the possibility of parole or to give him the death penalty.

Here's an excerpt from the article that appeared in yesterday's Chronicle:

"Quintero's defense team has worked to show he is not guilty of capital murder by reason of insanity.

Two psychologists and a neuropsychologist said a childhood fall caused brain damage that caused Quintero to perceive Johnson as a threat and take unreasonable action.

'Officer Johnson was a hero. He was a family man,' Recer said. 'We have an explanation. It's just not the quick, easy, bumper-sticker explanation the prosecution wants you to believe.'

Recer said she worked to figure out what was wrong with Quintero and what he was thinking.

'Because he sure wasn't thinking like any of us,' she said.

She said Quintero's 'bad brain' has an overactive threat-detection system, usually assuaged by drinking about 24 beers a day. But on that day, Quintero had about six beers.

Quintero acknowledged in a videotaped statement that, although his hands were cuffed behind his back, he shot Johnson while locked in the backseat of the patrol car."

Defense Argues Quintero Is Insane

Here's an update from the Houston Chronicle on the capital murder trial of Juan Quintero ("Experts clash over Quintero's sanity," May 6, 2008):

"Attorneys locked horns Tuesday in a battle of experts in the death penalty trial of Juan Leonardo Quintero, arguing whether the 34-year-old was insane when he shot Houston police officer Rodney Johnson in 2006.

Testimony of neuropsychologist Ruben Gur capped the defense case, saying that his tests reveal Quintero's brain is irregular and that irregularity may have contributed to psychological problems.

Prosecutors put on two doctors from a Houston medical imaging company who said they didn't see anything unusual about Quintero's brain.

The two sides clashed over whether Gur's work identifying brain problems was scientifically accurate. Prosecutors tried to show that Gur, a professor of psychology at the University of Pennsylvania, used methods that are still experimental.

Gur, and other witnesses for the defense, said Quintero has brain damage from a childhood fall.

Earlier Tuesday, Quintero's lawyer was held in contempt for withholding documents prosecutors said they were entitled to under the rules of evidence.

During an early morning hearing outside the presence of the jury, state District Judge Joan Campbell ordered that Danalynn Recer appear after the trial concludes to explain why she should not be held in contempt.

Campbell is expected to decide what punishment, if any, Recer should receive after the trial concludes.

The judge and Recer declined to comment, as did prosecutor Lyn McClellan.

David Lane, an attorney assisting Recer, said she forgot a doctor's report at her office, delaying the court about 10 minutes while it was faxed.

The documents involved the work of a doctor who testified Tuesday, bolstering assertions by a psychologist who told jurors Monday that Quintero was insane during the few minutes when he shot Johnson.

Prosecutors considered the report important for them to use during cross-examination of the doctor, D.L. Creson.

The defense team is trying to show that Quintero is not guilty of capital murder by reason of insanity.
Antonio Puente said Monday he believes the defendant meets the legal definition of 'insane.'

Quintero has acknowledged in a videotaped statement to police that he shot Johnson after being arrested in September 2006.

Quintero's attorneys have said he suffered brain damage in a childhood fall and that he shot Johnson because he perceived that the officer was a threat.

Johnson was shot seven times as he filled out paperwork in the front seat of his patrol car. Quintero was handcuffed and locked in the back seat.

Investigators have said Johnson searched Quintero, but overlooked the gun he had tucked in his waistband, after arresting him for not having a driver's license."

Another Mother Found Not Guilty by Reason of Insanity

According to the Fort Worth Star-Telegram, Valeria Maxon, who has been diagnosed with "bipolar disorder, most recent episode depressed with psychotic features," was found Not Guilty by Reason of Insanity (NGRI) in the drowning death of her son Alex ("Mansfield mom ruled insane in boy's death," May 2, 2008). As with the vast majority of successful insanity defenses, the prosecution and defense agreed on the appropriateness of this verdict, which was delivered by Judge Wayne Salvant. Insanity must be proved by a preponderance of the evidence.

The Star-Telegram article is pasted below in its entirety. Note the description at the end of four other tragic cases of Texas mothers who have been found NGRI since 2001 as a result of their severe mental illness.

"Valeria Maxon believed that she was a witch and that her 1-year-old son, Alex, was the Antichrist. She was certain that her only child was possessed by the devil, was dying and would start the apocalypse and bring about the end of the world.

Soon, according to psychologists who later examined Maxon, she became convinced that water was the only thing that could keep the evil spirits away and save the world.

So on June 30, 2006, while her husband was out running errands, Maxon put her son in the hot tub in the back yard of their Mansfield home and let him drown.

And even now -- nearly two years later -- Maxon thinks she did the right thing.

'She thought it was horrible but that it prevented the end of the world,' psychologist Randy Price testified Thursday during Maxon's capital murder trial.

Later, state District Judge Wayne Salvant found Maxon, 33, not guilty by reason of insanity and ordered that she be sent to a maximum-security state mental hospital in Vernon for treatment rather than to prison for punishment.

'This has been a tragic situation,' Salvant said. 'I'm hoping Mrs. Maxon can get the help that is needed.'

To be found not guilty by reason of insanity, defendants must prove that they suffer from a severe mental illness or defect and did not know their conduct was wrong at the time of their crime. In Maxon's case, no one -- including the prosecutors -- disputed that Maxon was legally insane when she drowned Alex.

'It is not my duty as a prosecutor to seek a conviction, but to see that justice is done," prosecutor Alana Minton said later. "I do believe that justice has been served today.'

Maxon's defense attorney, Joetta Keene, said that she is really a 'gentle soul whose mental illness took over.'

'That mental illness caused her to kill the love of her life,' Keene said. 'We are happy that the state and the judge saw that it was the mental illness that caused Alex's death and realized that Alex's mom loved him.'

During the trial, which was decided by a judge, not a jury, a Texas Ranger, two psychologists and Maxon's sister testified about Maxon's deteriorating mental state, the drowning and a weird tape-recording that was found in the Maxons' Mansfield home.

According to testimony, Valeria Maxon was living in Moldova in eastern Europe when she met her husband, Michael Maxon, through a dating service. She moved to the United States, and, on June 12, 2005, their son, Alex, was born.

In March 2006, they learned that Alex was developmentally delayed, and soon after, Valeria Maxon's mental health began deteriorating.

'She became more and more anxious about Alex,' Price testified. 'She wasn't able to sleep and was extremely concerned about him and she began to develop delusional thoughts.'

Psychologists testified that Maxon became convinced that her son was dying and that it was her fault because he needed her breast milk. She was certain Alex was possessed and would cause the end of the earth. She believed that God sent her a message, telling her water would prevent the end of the world and Alex's suffering.

Maxon was hospitalized at least five times, from May 16 through June 30, 2006, in psychiatric hospitals in Dallas, Florida and California. On June 6, 2006, she attempted suicide by overdosing on Ambien. Doctors diagnosed severe depression with psychotic features and told Michael Maxon not to leave her alone with Alex.

But on June 30, 2006, Michael Maxon left to run errands, and when he returned home, Alex was lying dead and naked on the couple's bed. Officials said Maxon called his wife's family in Europe, put away groceries and the dry cleaning, called a business partner and then dialed 911.

On Tuesday, Michael Maxon, 54, was charged with abandoning/endangering a child. Investigators accused him of leaving Alex alone with Valeria, knowing she was unstable.

At Thursday's trial, psychologists testified that they believe that Michael Maxon exacerbated his wife's mental condition. Police found a tape in the house in which Michael Maxon repeatedly chants negative statements. He told police he played it for his wife as 'therapy' when she was extremely depressed.

'It's all so deliciously tragic,' Maxon says over and over in a singsong voice. 'It's all my fault. I really screwed up. I'm the mother; no one understands me. If I'm miserable, the whole world has to be miserable. Nobody understands. Our son is riding the short bus. It's all my fault.'

WHAT DOES THE JUDGE'S ORDER MEAN?

Valeria Maxon will remain in the state mental hospital for an indefinite period. She will stay until a treatment team determines, and a judge agrees, that she is stable enough to be released. Sometimes, the stays are relatively short.

Other cases

Since 2001, at least four other Texas mothers have killed their children and were found not guilty by reason of insanity.

In June 2001, Andrea Yates of suburban Houston drowned her five children, ages 6 months to 7 years, in a bathtub, saying she was saving them from the devil. During her 2002 trial, a jury found her guilty of capital murder and sentenced her to life in prison, but the conviction was overturned. Yates, who had a long history of mental illness, was retried and found not guilty by reason of insanity. She was committed to a state mental hospital.

Deanna Laney of Tyler was charged with capital murder in May 2003 for bludgeoning two of her sons to death with rocks and severely injuring a third. She said God told her to kill her sons. Laney was found not guilty by reason of insanity and was committed to a state mental hospital.

Dena Schlosser of Plano fatally injured her daughter by cutting off her arms with a 10-inch butcher knife in November 2004. Schlosser, who suffered from postpartum depression and exhibited hyper-religious behavior, believed she was sacrificing her baby to God. She was found not guilty by reason of insanity and sent to a state mental hospital.

Lisa Ann Diaz of Plano drowned her two daughters, ages 5 and 2, in 2003. She told doctors and psychologists that they had lupus and ringworm. She was found not guilty by reason of insanity and was released from a state mental hospital in 2006."