Lindsay Clancy sent her husband out for takeout, mapping how long the errand would take. Prosecutors say this proves she planned to kill her three children. Her defense says she was in the grip of postpartum psychosis. Her trial is scheduled to begin in July 2026, and the question at its center is one the courts have grappled with before: Can someone who plans a killing still be legally insane?

The assumption that planned violence equals sane violence is intuitive. It is also incorrect.

The Precedent: Andrea Yates

Andrea Yates drowned her five children on June 20, 2001. Her actions were purposeful and methodical. She waited for her husband to leave for work. She filled the bathtub. She brought each child to the water, one by one, starting with the youngest. She laid their bodies on the bed and covered them with a sheet. Then she called 911.

Yates knew what she was doing was against the law. She expected to be arrested. And yet, on retrial in 2006, she was found not guilty by reason of insanity.

How? Because Yates believed her children were spiritually damaged and would burn in hell. By killing them before they reached the age of accountability, she believed she was saving their souls. Her planning, i.e., waiting for her husband to leave, preventing the family dog from interfering, was meticulous. But every element of that planning served her delusional mission. The method was rational. The premise was psychotic.

The Paradox of Rational Planning Within Irrational Belief

When we think about violence committed by someone who is hearing voices or influenced by delusions, we imagine chaos: a sudden eruption, a person lashing out at a perceived threat. And it’s true; research shows that over half (around 54 percent) of violence in forensic psychiatric settings is impulsive. But that leaves a substantial minority that looks very different.

Planning reflects cognitive capacity. It does not, by itself, reflect an accurate perception of reality. Anyone who’s conducted as many insanity evaluations as I have has seen extremely rational planning within an irrational delusional belief system. A study of homicides committed by individuals with schizophrenia found that about 43 percent showed clear elements of premeditation, yet many were found not criminally responsible because the premeditation occurred within a psychotic framework.

A person can execute a methodical plan in service of a delusion. The planning was real. But the reality within which the planning occurred was not.

Knowing vs. Appreciating Wrongfulness

The legal standard for insanity asks whether the defendant knew or appreciated that their act was wrong. There is a meaningful difference between these two.

Consider someone who delusionally believes God is commanding them to sacrifice their child. They might carry out that act with full awareness that the law would not understand. They know it’s illegal. They expect to be arrested. But within their delusional framework, they believe they are doing something righteous. They acknowledge the legal wrongfulness; they cannot appreciate the moral wrongfulness.

This distinction was central to the Yates case. She knew drowning her children was against the law. But she could not appreciate that it was morally wrong because, in her psychotic state, she believed she was rescuing them from eternal damnation.

The Questions Forensic Evaluators Ask

Criminal responsibility evaluation requires establishing a causal link between mental illness and criminal behavior. Some defendants commit crimes as a direct response to psychotic symptoms, delusions that make the violence seem necessary or justified. Others have mental illnesses that are incidental to the offense. Only the first pattern supports an insanity finding.

What did the defendant say before, during, and after the offense? Statements made at the time carry significant weight because they are less susceptible to fabrication. When 18-year-old Damian McElrath killed his mother in 2012, he immediately wrote a note explaining she had “admitted” to poisoning him for years. He called 911 and asked the dispatcher if his actions were wrong. These contemporaneous statements, reflecting his longstanding delusion, helped establish the causal link. A Georgia jury found him not guilty by reason of insanity, a verdict the U.S. Supreme Court upheld in 2024.

Who was the target, and why? Research shows defendants found not guilty by reason of insanity are more likely to victimize family members, with paranoid delusions as the motive in about two-thirds of cases. Those found guilty have conventional motives: revenge, jealousy, economic gain.

What did the defendant do after the offense? Attempts to evade or conceal suggest an awareness that the act was prohibited, but awareness of illegality is not the same as appreciation of moral wrongfulness. Defendants found not guilty by reason of insanity are significantly less likely to flee or conceal evidence. Both Yates and McElrath called the authorities themselves. Neither ran.

The Bottom Line

Evidence of premeditation is a factor in determining criminal responsibility, but it is not dispositive. The critical question is whether severe mental illness prevented the defendant from appreciating, not just knowing, that what they were doing was wrong.

Psychosis and planning can coexist. When they do, the question is not whether the defendant could plan. The question is what reality they were planning within. That is the question Lindsay Clancy’s jury will have to answer.