Glossary

Legal and clinical terms as they were used in this case. Definitions are drawn from how the sources in this corpus used them, not from a treatise; where a source gave a definition it is cited.

Massachusetts criminal law

Criminal responsibility, the McHoul standard. As Sullivan instructed the jury: "A person is not criminally responsible for her conduct if she has a mental disease or defect, and as a result of that mental disease or defect, lacks the substantial capacity either to appreciate the criminality or the wrongfulness of her conduct or to conform her conduct to the requirements of the law." The disease "need not fit into a formal medical diagnosis." Once raised, the Commonwealth must prove sanity beyond a reasonable doubt. "Appreciate" means "meaningful understanding and intelligent comprehension," not mere intellectual awareness. Used in about 1 percent of felony cases and successful about a quarter of the time. [S121][S134]

Lack of criminal responsibility. The Massachusetts term for what is commonly called the insanity defense. The defense filed its notice on 2024-12-13. [S161]

Deliberate premeditation; extreme atrocity or cruelty. The two theories of first-degree murder submitted here; either suffices. First degree carries life without parole and automatic SJC review. [S28][S133]

Second-degree murder. Murder without either theory; life with parole eligibility, minimum set by the judge at 15 to 25 years. [S121][S133]

Manslaughter. Per CNN, intentional "wanton or reckless conduct" causing death, up to 20 years. The charge conference refused an involuntary manslaughter instruction yet manslaughter went to the jury. See 08-open-questions.md. [S121][S28]

Required finding of not guilty. A directed-verdict motion. Denied on 2026-08-17 when the Commonwealth rested; Reddington is expected to renew it on 2026-09-29. [S104][S119]

Tuey-Rodriguez charge. Massachusetts's version of the Allen "dynamite" charge, given when a jury reports deadlock: keep working, listen to one another, but do not abandon honestly held views; "there's not a better jury than you." Once given, a judge cannot send the jury back again on a further deadlock report. Given Wednesday 2026-09-02. [S20][S48][S136]

Bowden charge. An instruction permitting the jury to consider the adequacy of the police investigation. Requested by the defense; refused. [S28][S107]

Section 12. G.L. c. 123, s. 12, emergency involuntary psychiatric hospitalization. Tufts testified she saw no grounds for it at any appointment. [S35]

Section 18. G.L. c. 123, s. 18, hospitalization of a person in custody with mental illness. The basis for Clancy's May to November 2023 commitment at Tewksbury. [S174]

Section 16. G.L. c. 123, s. 16, the commitment process after a not-criminally-responsible finding: evaluation, hearing, six-month initial commitment, annual reviews, no maximum. [S121][S133]

Bifurcation. Splitting a trial into a guilt phase and a responsibility phase. Sought, denied, reconsidered, denied again. [S145][S148]

Stipulation. The 2026-08-04 agreement that the Commonwealth need not prove chain of custody for blood, fluids, the bands and DNA. Not a guilty plea and not an admission of responsibility. [S70]

Impoundment. The court's sealing of the 911 call and autopsy photographs from public distribution (2026-07-24) and of the juror list for 14 days (2026-09-04). [S137][S119]

Rule 14. The Massachusetts criminal discovery rule governing reciprocal exchange of expert materials in mental-health defenses. [S160]

Single justice. One SJC justice sitting alone on emergency matters. Justice Wendlandt heard the 09-04 petition. [S122]

Daubert-type challenge. The defense's objection to Saathoff's qualifications, overruled. [S109]

Manifest necessity. The standard permitting retrial after a mistrial; a genuine deadlock is the classic case. Relevant to the defense's stated double jeopardy theory. [07-legal-issues.md]

Medical malpractice tribunal. A Massachusetts screening panel (judge, physician, attorney) that decides whether a malpractice claim has enough evidence to proceed. Requested by Tufts. [S186]

Clinical terms

Postpartum psychosis. Per the Cleveland Clinic as cited by AllSides, 1 to 3 per 1,000 live births. The defense diagnosis, on a bipolar substrate. The Commonwealth's experts disputed it, and Mack used a four-week postpartum window. [S183][S96]

Bipolar II. Heilbrun's diagnosis. Saathoff also found bipolar disorder; Mack found none. [S106][S118]

Altruistic filicide. Heilbrun's alternate theory: "killing your kids out of love... so that they wouldn't have to suffer." [S108]

Command hallucination. A voice ordering an act. The defense's account of the night; the Commonwealth argued its timing and cessation were atypical. [S9][S17]

Adversarial allegiance. The tendency of retained experts to read evidence in favor of the side that hired them. [S118]

Petechiae. Pinpoint hemorrhages from pressure; found in the children's faces, eyelids and lips. [S169][S32]

Jefferson fracture. A burst fracture of the C1 vertebra, from her head-first fall. [S105]

Polypharmacy. The civil complaints' term for the thirteen drugs. [S84]

Black box warning. The FDA's strongest warning; on Zoloft for suicidality in young people, which Tufts said did not apply at her age. [S19]