Yates v. State

Andrea Yates (defendant), who had a long history of severe postpartum depression, psychosis, and hospitalization, drowned her five children after her mental health rapidly deteriorated despite treatment and warnings that another pregnancy risked another psychotic episode. She was tried for capital murder and rejected an insanity defense; the jury convicted her. After the verdict but before sentencing, it emerged that the state's mental- health expert had falsely testified about a nonexistent Law & Order episode depicting a postpartum-depression mother who drowned her children and was found insane — testimony the prosecution referenced twice more, in another witness's examination and in closing argument. Yates moved for a mistrial, which the trial court denied.

Whether a new trial should be granted when, after the verdict but before a motion for new trial is decided, a witness who gave material, inculpatory testimony against the defendant admits by affidavit that the testimony was false.