Postpartum psychosis is not postpartum depression
[NOTE: For now, the Clancy case is on hold. But discussions about it aren’t on hold. This post isn’t specifically about that case, however. Rather, it’s about a topic connected with the Clancy case but not specific to it.]
I’ve noticed a great deal of confusion about postpartum depression versus postpartum psychosis. The two are different entities.
Postpartum psychosis is rare and postpartum depression is common. With postpartum psychosis, the sufferer is more likely to be at risk for harming or killing her children even through she has shown nothing but love and caring for them in the past. Postpartum psychosis does not lead to random assaults, when it does lead to crimes. It leads to child harming or child murder, usually under the sway of a delusion of some sort, and often coupled with suicide attempts or completed suicides.
See this:
The postpartum period is the time of highest risk in a woman’s lifetime for the development of a mental illness. Although the Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition, Text Revision (DSM-IV-TR) defines the postpartum period as the immediate, relatively short time following delivery, in research studies this period has been defined as ranging from a few days to 12 months.
Postpartum-onset psychological problems generally fall into one of three categories: so-called baby blues, postpartum depression, and postpartum psychosis. Baby blues affect up to 70 percent of mothers and include mild symptoms of crying and irritability which end by the second week after childbirth. Postpartum-onset depression affects from 7 to 15 percent of mothers and is characterized by sadness, crying, self-blame, loss of control, irritability, anxiety, tension, and sleep difficulties. Factors such as personality, negative feelings toward the infant, marital discord, poor social supports, and ambivalence over parenthood appear to predispose women to the onset of depressive symptoms in the postpartum period.
Postpartum psychosis, the most severe of postpartum mental disorders, occurs in 1 to 2 of 1,000 births and frequently requires hospitalization to stabilize symptoms. … The disorder is characterized by an extended period of loss of contact with reality that may include auditory or visual hallucinations, delusions, or rapid mood swings. The auditory and visual hallucinations may focus on violence toward self or the infant.
Risk factors for postpartum psychosis can be of both biologic and genetic origins. One study found that the rate of postpartum psychosis in mothers with bipolar disorder was 26 percent, with the rate in mothers with bipolar disorder and a family history of postpartum psychosis increasing to 57 percent. …
… [R]esearch supports that postpartum psychosis is associated with prominent cognitive disturbances, ranging from mental confusion and indecision to intrusive and bizarre thoughts. Women with this disorder can appear delirious and disorganized. Second, symptoms can arise and dissipate suddenly, with the woman appearing lucid one moment and psychotic the next. Third, although DSM-IV-TR classifies it as a psychotic disorder not otherwise specified, research shows that the syndrome can have both affective and psychotic components.
It has been estimated that four percent of women with postpartum psychosis commit infanticide. …
The insanity defense is successful in less than 0.1 percent of all criminal trials. However, major population studies, including McKee and Shea, d’Orban, and Bourget and Bradford, found insanity pleas successful in 20, 27, and 15 percent of infanticide cases, respectively. These results suggest that, regardless of the legal or medical guidelines, the law treats women who kill their children with more leniency. Nonetheless, infanticide case outcomes vary extremely. At least two such women have been sentenced to death, whereas some have been released without a prison sentence
That article is from 2012, and the review of cases goes back a ways before that. So we’re not talking about the result of recent internet social media hysteria influencing trials. Most of the data almost certainly predates the ascendance of social media.
You may decide that postpartum psychosis is a myth promulgated by those who wish to avoid punishment for killing their children. I think that underestimates the power of psychosis in general and this type of psychosis in particular. Note also that, as a defense to child murder, it’s most often unsuccessful. It certainly would be far less likely to be a successful defense in cases in which there is no history of deep postpartum disturbance and the seeking of psychological help prior to the murders.
Note also that postpartum psychosis is already very rare, and in that small group 4% go on to murder their children, which makes that phenomenon exceedingly rare indeed. However, I’ve seen people in discussion groups involving the Clancy murders to state that 50,000 women kill their children in the US every year. That bears no resemblance to the actual figures, which are much smaller although still profoundly disturbing:
Between 1976 and 2004, 30 percent of all children younger than five years old who were murdered were killed by their mothers, while 31 percent were killed by their fathers. A study by Brown University showed that from 1976 to 2007, on average, there were 500 cases of filicide a year in the United States.
So that 50,000 figure overstates filicide by a huge factor. Plus, mothers account for about half of the actual figure. This is in marked contrast to the much more lopsided statistics between the sexes for crimes of violence in general.
Nor is the idea of postpartum psychosis as connected with child murder an especially new one:
In the United States, psychiatrists recognized the significance of recent childbirth in acts against infants. In 1927, the field divided infanticide based on whether the mother was still lactating, or breastfeeding. Many cases were attributed to exhaustion or what was then called lactation psychosis, a recognition that hormonal changes and the stress of parenting a newborn could affect one’s well-being.
That article cites a different statistic for filicide in the US – a higher one, although still far short of 50,000 a year:
The Washington Post cites a Brown University study in 2014 that found three thousand filicides occur each year in the United States.
The following are the categories of motivations for maternal filicide (not just for filicide in which the perpetrator claims postpartum psychosis – this is for filicide in general):
Resnick, in his 2016 study, found that mothers who kill their children have one of five motives: altruistic filicide, or the belief that the child is better off dead (usually because the parent intends to commit suicide and does not wish to leave the child alone or because the child has a real or perceived disability); acutely psychotic filicide, or no understandable reason; fatal maltreatment filicide, when a mother abuses the child but does not necessarily intend to kill the youngster; unwanted child filicide, when a mother wants to be free of the child she feels is holding her back (possibly because a new partner does not want stepchildren or the parent seeks a benefit such as insurance money); and spouse revenge filicide, when a mother kills the child to wound the father for actions such as abandonment or infidelity, as in the myth of Medea. Altruistic filicide is the most common—Resnick found that it accounted for 49 percent of the cases reviewed—while spouse revenge filicide is the rarest at 2 percent. Among maternal infanticides, or the killing of a child younger than one year, perpetrators were often unemployed women in their early twenties.
My perception of the Clancy case is that most people who defend Clancy and think she was not criminally responsible believe that her motive was that she was acutely psychotic, period. On the other hand, those who believe she’s guilty of murder tend to believe that her motive was either the first – altruistic suicide – or unwanted child filicide (that she wanted to rid herself of inconvenient children cramping her style in some way).
There are also some Clancy-defenders who believe she didn’t even do it, but that falls into a different category entirely. In addition, there are some people who think Clancy should be found guilty who believe that even if she was psychotic it should not absolve her of any criminal responsibility.
Another high-profile case of maternal filicide and claimed mental illness was that of Susan Smith, in which it seems fairly clear that it was actually unwanted child filicide; Smith was found guilty of murder. She had also distinguished herself by claiming a black man had kidnapped her children:
On October 25, 1994, Smith reported to police that she had been the victim of a carjacking by a black man while driving her 1990 Mazda Protégé sedan with her sons – Michael, aged three, and Alexander, aged 14 months – still in the back seat. For nine days, she made dramatic pleas on national television for their safe return. However, following an intensive investigation and a nationwide search for them, she confessed on November 3, 1994, to letting her car roll into nearby John D. Long Lake, drowning them inside. Her motivation was reportedly to facilitate a relationship with a local wealthy man named Tom Findlay. Prior to the murders, he sent her a letter ending their relationship and expressing that he did not want children. She said there was no motive nor did she plan the murders, stating that she was not in a right state of mind.
Very different fact situation.
As I understand it, the legal standard for an insanity defense in Massachusetts is whether a mental defect deprived the defendant of either: (i) the capacity to know that their actions were wrong; or (ii) the capacity to act according to the law.
That standard isn’t the same as postpartum psychosis, and I think that’s the root of a lot of confusion. It strikes me as eminently possible that a person could be both suffering from postpartum psychosis AND fail to meet the legal standard for not guilty by reason of insanity. My best evidence for this supposition is neo’s point that only 4% of people suffering from postpartum psychosis murder their children.
Now is it just for a person suffering from postpartum psychosis to also be criminally liable because they failed to meet the standard for an insanity defense?
When the big picture is considered, its difficult to say no. There are many, many people who have a more difficult time following the law than others, whether its due to genetics, culture, the way they were raised, mental conditions that no one would consider to constitute legal insanity like depression, etc.
From what I read in the trial transcript, Clancy only claimed to have a single psychotic episode, the one in which she killed her children, and did not have one before or since.
The specificity of the timing of this postpartum psychosis is astonishing, waiting for months to appear until her husband is out of the house and then never coming back again.
In addition, she described a command hallucination that did not tell her specifically what to do (only the outcome), and that appears to have never returned after she delivered that outcome. The voice did not tell her how to kill her children, did not tell her to dissemble to her husband on the phone, to extend his errand, to take the children to the basement, to lock the basement door.
People who experience command hallucinations a) frequently do not obey them, and b) obeying the commands does not make them go away.
In my view, the issue isn’t really whether she was suffering from psychosis or not.
I mean, it is important to determine whether she understood what she was doing at the time to determine whether she spends the rest of her life in prison, or the rest of her life in a hospital, but the true issue to me is that someone who is capable of murdering their own children with their bare hands, regardless of whether while perfectly lucid or while in the throes of psychosis, cannot be trusted to be free in society ever again.
Let’s just say I don’t have enough confidence in the field of psychiatry and mental health to just accept it when some shrink says “she’s cured, she can be around your kids and grandkids now”.
She has proven she is capable of ultimate evil. No psychiatrist in the world can absolutely guarantee that she will never succumb to psychosis and be driven to murder again. Therefore, she should never set foot outside an institutional setting for the rest of her life. Whether her room in that institution has bars or padding on the walls is irrelevant to me.
As I said, I wasn’t primarily writing about the Clancy case.
And yet, just to respond to some of the above comments, Clancy’s mental health issues were not limited to postpartum psychosis. Nor does psychosis preclude planning, nor a single episode in a person otherwise very deeply disturbed (she was also bipolar, for example).
Plus, as I’ve written before, in Massachusetts she does not have to prove this. The prosecution has the burden of proof to prove she was not this way. It’s a very high burden for the prosecution, not the defense.
The post is about the phenomenon of postpartum psychosis.
Science does not, cannot, discern origin and expression. Sailorcurt is right, all we know with certainty is that she is disposed to entertaining abortive ideation and taking affirmative action to relieve a “burden” of state and mind. In this case, planned parenthood. The alternative conceptions of human consciousness deny dignity and agency. Either way, it is an article of faith. Who or what do you trust?
@neo:And yet, just to respond to some of the above comments, Clancy’s mental health issues were not limited to postpartum psychosis.
If indeed they included postpartum psychosis. There is only her word for a single episode of that, and it coincides entirely with the roughly twenty minutes it took to commit a heinous crime. Contrast with Andrea Yates:
That Clancy had other mental health issues, like tens of millions of people who have killed no one, is not disputed.
An interesting discussion of psychiatric history and theory. Thanks.
The question many are asking themselves is whether laws should exonerate killers of guilt based upon their mental condition at the time of the crime. Massachusetts law requires the state to prove beyond doubt that mental condition did NOT prevent the killer from knowing the law and following it. Other states require the defendant to prove that it did.
My inclination is to agree with Sailorcurt @12:47 p.m. The killing calls for the killer to be removed from society for its safety.
@Kate:Massachusetts law requires the state to prove beyond doubt that mental condition did NOT prevent the killer from knowing the law and following it.
Beyond reasonable doubt. Her law-abiding behavior before and after the twenty-ish minutes needed to kill the children as well as the initiative she displayed in not getting caught or being prevented might to a reasonable person, indicate that her mental condition did not prevent her from conforming her behavior to the laws, beyond a reasonable doubt.
To some, a mysterious episode of medical inability to abide by laws that lasts only for the twenty-ish minutes needed for execution of the crime, and never seen before or since, would be an unreasonable doubt. True it’s not as unreasonable as thinking her husband might have orchestrated it, or that the Men In Black did it and altered her memories. But this is why we have juries.
This is why some of us are concerned that a hospital stay might not be so long for Clancy as some are trying to persuade us it would obviously be. It was only one episode of psychosis, according to her. She’s on medication now and seems to be doing okay. Why shouldn’t she be let out after six months? They can’t use what she did to keep her there. They have to use how she’s doing at the time. And she’s seems to be doing just fine as regard to murder impulses and hearing voices.
Just enough psychosis to not be found guilty, but not enough to keep her in the hospital so long as Andrea Yates.
Niketas:
I have definite reasonable doubt in the Clancy case,. You don’t think doubt in this case is reasonable, but that does not make you correct.
I have written many posts on why I think there is reasonable doubt, so I won’t waste time here repeating myself.
However, I will add that I studied the law of this back in law school, and I also have my training as a therapist, and I have long thought there is no good solution to the problem of psychosis and crime. There is a wide variety of legal approaches – very wide, actually – all with pros and cons and all unsatisfactory.
The one I prefer is to sentence the person, and if there is diminished responsibility because of a psychosis, the person starts serving the sentence in a mental hospital and finishes out the term in prison when the hospital deems the person recovered from the psychosis, with the total in both institutions being the time served. It’s not a great solution at all, but I think it is probably better than the others.
@neo:I have definite reasonable doubt in the Clancy case,. You don’t think doubt in this case is reasonable, but that does not make you correct.
I never said it did, of course, because “correct” is the wrong concept. The question of whether a doubt is “reasonable” is fundamentally not a factual question, but a judgment, and reasonable people don’t judge identically even if all are operating from the same set of facts. Few people in this case besides the jury have reviewed the entire set of facts presented to the jury, and even they do not agree.
Reasonable people can disagree about such things, which is is why we have juries to decide these things, and we know they don’t always get it “right”.
There is a wide variety of legal approaches – very wide, actually – all with pros and cons and all unsatisfactory.
Certainly there are.
finishes out the term in prison when the hospital deems the person recovered from the psychosis
That sounds like a much better law than Massachusetts has, since the jury’s choices were only murder 1, murder 2, manslaughter, not guilty, and not guilty by lack of criminal responsibility. They’d had to have some kind of “guilty but insane” option and I believe 12 states have such a thing, but not Massachusetts.
Neo: “The one I prefer is to sentence the person, and if there is diminished responsibility because of a psychosis, the person starts serving the sentence in a mental hospital and finishes out the term in prison when the hospital deems the person recovered from the psychosis, with the total in both institutions being the time served. It’s not a great solution at all, but I think it is probably better than the others.”
I agree. It’s sad that state legislators in Massachusetts don’t.
Sailcourt and Kate–fear not.
Mothers who kill their children can safely be in society–they aren’t going to kill you, your children, or your grandchildren.
They only kill their own children.
(I’m being factual, though that reads as deeply sarcastic.)
@Lee:They only kill their own children.
At least one time a mother killed her children, was found not guilty by reason of insanity, was released from the hospital, had more children, and then killed them too 12 years later and found not guilty by reason of insanity again. After each set of murders she attempted suicide, and in the end escaped from the mental hospital and drowned.
I don’t know of another like it, and it was a very long time ago.
Lee:
” … can safely be in society.”
Sounds like Massachusetts logic. Sleep well, they don’t kill Lees. Don’t worry, Lee is absolutely certain and will stake a life on it. Someone else’s.
I was born in 1954, indeed, a very long time ago.
Is the filicide psychosis dormant while no children are around? Is it used up, or something, with the first filicide? All gone? We bet what on a “yes” answer?
“there are some people who think Clancy should be found guilty who believe that even if she was psychotic”
Yep!
The sentence may be a different matter (hanging or firing squad may be appropriate here), but “guilty” nonetheless. A person committing such an extreme crime should not be permitted in public again – we don’t know enough about such mental conditions to determine “cured”, especially for an incident that “happened” once in 42 years and only for the duration.
And for a crime of this nature … ?
“Too much tolerance is not a virtue”
May I point out that figures suggest an imprisoned male child murderer may not live long enough to finish the sentence. (and note, it’s often prison, not a mental hospital, for males committing filicide)
DT:
You write, “and note, it’s often prison, not a mental hospital, for males committing filicide.”
And note, it’s also often prison, not a mental hospital, for females committing filicide. Here are the figures I quoted in my post:
That’s still very much a minority. Most go to prison.
Another thing is that men committing filicide sometimes do go to mental hospitals. There isn’t too much research on this, but (at least according to Google) this article found that 14% to 17% of fathers committing filicide get sent to mental hospitals instead of prison. So although mothers have successful insanity defenses more often than fathers do, it doesn’t seem to be that much more often.
What’s more, men who commit filicide often have a history of violence against other people, and have a revenge motive in a custody battle.
Richard Aubrey:
There is no psychiatric diagnosis called “filicide psychosis.”
But to answer what I think is your actual question, plenty of people who kill their children have a pre-existing diagnosis involving what was traditionally known as a psychosis. For example, this is the psychiatric history of Andrea Yates, who drowned her five children:
Please read the whole thing. Among other details, even though she was psychotic, she was capable of planning and exhibited planning.
My understanding from other articles on the case is that the jurors are allowed to return other, lesser verdicts under Massachusetts law – second-degree murder or manslaughter, for example. And the one intransigent juror opened an opportunity to discuss a lesser sentence – but it seems that a hard core of jurors made this an all-or-nothing feminist-tinged struggle session… that is certainly what the defense attorney did and continues to do.
… so the shocking point to me is that the other 11 jurors were willing to completely ignore the deaths of the children in their moral reckoning…. they felt no need for that horror to have *some* expression in their ruling.
The very thought of filicide turns my stomach. I don’t care about the clinical debate about post partum psychosis; someone who murders the defenseless young that she is supposed to care for as Clancy did should be executed without decades on Death Row. Clancy drowned her children one by one? Watched them struggle to breathe? Yuck.
Ben David:
I disagree. If they found that she was not guilty of murder, because of diminished responsibility, the same would be true of manslaughter, etc.. Convicting her of lesser charges would only apply if they found she was responsible and that it was proved beyond a reasonable doubt that her mental problems did not affect her legal responsibility.
This case indicates to me how irrational many people on BOTH sides are, and how little they understand the law in Massachusetts. Granted, I think it’s a confusing law and it’s also a pretty bad one, IMHO, but if you’re on a jury you’re supposed to follow it.
I plan to publish a post on this, maybe tomorrow.
Sorry Neo; I often agree with you but not on this one.
The Clancy case: The only thing “proven” to the masses (us) is that this woman killed her three children as a deliberate act (granted, we’re not on the jury – but this jury didn’t dispute the murders). I don’t see that anything else matters. Mentally ill to this degree? Cull the herd. Is there something else to be considered? Perhaps, but it’s not been made public. Maybe I’d change my mind if something tremendous came out – but I’m sure if such existed, it would be known by now.
What law? If I’m on a jury and I firmly believe the party on trial is guilty and not insane, why should I change my opinion? Jury nullification is still valid, is it not? Is not a jury above the law to a certain extent?
I would not be an acceptable juror to the defense in such a case; as Doonesbury once said: “Guilty, guilty, guilty” – right up front. Only thing to be decided is how and when the execution takes place. Why waste the limited resources of the mental health professionals on such an extremely defective soul?
Too late for a second trial; probably couldn’t find 12 people that aren’t aware of the case and the politics surrounding this case would put unreasonable pressure on all involved.
@DT:The only thing “proven” to the masses (us) is that this woman killed her three children as a deliberate act
The evidence that Clancy has serious mental health issues, as do tens of millions of people who do no murders, is strong. The evidence that she actually ever had a psychotic episode is weak, and the evidence that even if she had a psychotic episode, she was also because of it unable to conform her conduct to the law, is even weaker.
Her single psychotic episode of only twenty-some minutes, timed for when her husband was out, and her claimed inability to not murder her children during it, are established only by her unsupported word, and both if true would make her an extremely unusual case. It seems almost designed to maximize her chance of being found not guilty and minimize the resulting involuntary hospitalization.
If a person’s unsupported word is all it takes to trigger such a high burden of proof in Massachusetts then I don’t understand why every criminal doesn’t invoke it, as was supposed to have happened with “benefit of clergy” in old times.
If I say I was psychotic only during the twenty minutes I committed a crime who can prove me wrong? There is some disconnect here about how “reasonable doubt” is supposed to work. From the judge’s instructions in the trial transcript:
To say, as the defense did, that Clancy or anyone else is a perfectly law-abiding person before and after the twenty minutes it took to commit a crime, but that during that twenty minutes when her husband was away she was the victim of something that had never before happened to her and has not happened since, which when it happens is usually very different from how she claims it happened in her case, and during that twenty minutes she was deprived of the ability to conform to the law but not deprived of the ability to time, plan, dissemble, and deceive in order to commit the crime without being stopped: that to me sounds like an unreasonable doubt.
Niketas:
Psychosis always relies on a person’s word. People can always be malingering. So there can be no “proof.” Nor does Massachusetts law require proof.
In addition, I don’t think most people understand the concept of reasonable doubt. Of course one can come up with a scenario where Clancy is a cold-blooded killer who plotted this with malice aforethought and evil intent, purposely wanting to be rid of her kids. But then you have to explain how a woman who, until these very severe and well-documented mental/emotional problems hit her, was know by everyone who knew and observed her to have been a good and loving mother, could flip into being an evil psychopath for that moment. To me, it seems obvious there is reasonable doubt that that happened, and a psychotic break is the more likely explanation. Even if it’s just as likely, or even less likely, in Massachusetts as long as it’s plausible you must rule not guilty by reason of incapacity.
You may dislike the Massachusetts law. But that’s another story and has nothing to do with what verdict the jury should have come up with under that law.
@neo:People can always be malingering. So there can be no “proof.”
But you can observe behavior consistent with psychosis, and as you saw from the transcript I quoted no such behavior was observed for Clancy before or after. Not only that, she did not report the experience of psychosis before or after. Not only that, she denied any psychosis before or after. She only claims just enough psychosis for twenty minutes while her husband is out.
everyone who knew and observed her to have been a good and loving mother, could flip into being an evil psychopath for that moment.
Unfortunately people who are not “evil psychopaths” do indeed murder people, sometimes even children, we don’t need to assume a “psychopath switch” any more than we need to assume a “psychotic episode switch” to know beyond reasonable doubt that she knew it was wrong to murder her children, was able to not murder her children, but still did it. We can judge that from evidence of observed behavior and the totality of the other evidence consistent with the judge’s instructions I quoted.
Even if it’s just as likely, or even less likely, in Massachusetts as long as it’s plausible you must rule not guilty by reason of incapacity.
Firstly, I’m sure you know that psychosis is not sufficient for incapacity. Lots of people in psychosis know what is wrong and resist doing wrong. I already quoted from the transcript so won’t repeat. The judge emphasized this is a legal and not a medical judgement:
Secondly, to me it is not plausible that this “psychotic break” is so specific and unique to this one person in this one situation and has such a specific effect and happens only the one time needed to avoid guilt. Already quoted from the transcript, once from defense witness and once from prosecution witness, see above.
This mysterious and sudden episode never seen before or since doesn’t make her think President Trump is calling her instead of her husband, it doesn’t make her think demons have taken the form of her children and have to be killed, it doesn’t make her look at the clock and think it’s 3 am instead of 5 pm, it specifically only “makes” her do one thing–three times–which it does not tell her how to do and leaves all her executive and social and other capabilities unaffected so that she can get that thing done effectively and efficiently in a short time, telling all needed lies and watching the clock and estimating time and distance with her husband none the wiser that anything is wrong despite speaking with her on the phone. I do not find that plausible.
Judging from her behavior before and after she was at all other times perfectly able to conform her behavior to laws. I could find no reference in the trial transcript to her breaking laws, rules, social norms, etc.
Sometimes people do evil things and we don’t understand why, but that does not mean they are not responsible for their actions. That I don’t understand that someone would know killing her own children is wrong and still do it does not make it implausible, because it happens.
Neo.
Okay. There is no specific diagnosis of filicide psychosis. So….either filicide happens without a psychotic episode, or one or another psychotic episode allows for filicide. We’re told Clancy is not guilty because she was in the latter situation. Some kind of psychosis led, in this case and due to circumstances, to filicide. So, had there been no kids available, what would have happened? Does the psychosis await some other set of circumstances which will allow/trigger some other horrid crime? In either case, filicide-specific or not, is it used up after the crime?
I guess my question is…does she get life in prison or life in a mental institution. And, in the latter case, would she be eligible for release if a psychologist or boad thereof felt she was no longer a threat?
@Niketas
@Lee:They only kill their own children.
At least one time a mother killed her children, was found not guilty by reason of insanity, was released from the hospital, had more children, and then killed them too 12 years later and found not guilty by reason of insanity again. After each set of murders she attempted suicide, and in the end escaped from the mental hospital and drowned.
I don’t know of another like it, and it was a very long time ago.
As I wrote–and you documented–they kill only their OWN children.
Sterilization makes more sense than prison.
More sense to Lee, not to me, or maybe thee?
Fredr-nic cited a case from 1954, not 1754.
So there is some magic trait that make the murder of one’s offspring less horrific, than say, foster children, or those unrelated souls a fiend is paid to care for?
om. Apparently. No idea why.