# Is there a legal precedent accepting PMDD for not-guilty-by-reason-of-insanity plea? **URL:** \ **Category:** Factual Questions\ **Created:** [April 29, 2005, 6:09pm UTC](https://boards.straightdope.com/t/is-there-a-legal-precedent-accepting-pmdd-for-not-guilty-by-reason-of-insanity-plea/301746 "2005-04-29T18:09:58Z")\ **Posts on this page:** 3\ **Page:** 1
**Author:** ![Hostile\_Dialect](https://avatars.discourse-cdn.com/v4/letter/h/e495f1/32.png) [@Hostile\_Dialect](https://boards.straightdope.com/u/Hostile_Dialect)\ **Post date:** [April 29, 2005, 6:09pm UTC](https://boards.straightdope.com/t/is-there-a-legal-precedent-accepting-pmdd-for-not-guilty-by-reason-of-insanity-plea/301746/1 "2005-04-29T18:09:58Z")
Having read [this article](http://www.straightdope.com/columns/050429.html), which describes Sandie Craddock, the 29-year-old London felon who committed her crimes exclusively while premenstrual and skated with manslaughter instead of murder 1 on condition of continuing hormone therapy; and also having seen an episode of _Law & Order: Special Victims Unit_ in which a girl potentially stood to skate free on murder of her mother because she suffered from PMDD at the time; I’m wondering if there’s a legal precedent, in the USA or elsewhere, for a not-guilty-by-reason-of-insanity verdict being handed down to a woman who committed a crime while in the clutches of PMDD. For those who don’t know and are too lazy to read the article, PMDD, or premenstrual dysphoric disorder, is a mental illness not currently recognized in the DSM, reportedly affecting 2 to 10 percent of women, who find themselves absolutely unable to control their actions or tell right from wrong during their premenstrual period. This question is not about the validity of PMDD, but rather about whether courts of law have ever accepted it (or something very similar to it like Craddock’s case) as a reason to actually put down a not-guilty verdict. ---
**Author:** ![Schnitte](https://sea3.discourse-cdn.com/straightdope/user_avatar/boards.straightdope.com/schnitte/32/9033_2.png) [@Schnitte](https://boards.straightdope.com/u/Schnitte)\ **Post date:** [May 1, 2005, 10:22am UTC](https://boards.straightdope.com/t/is-there-a-legal-precedent-accepting-pmdd-for-not-guilty-by-reason-of-insanity-plea/301746/2 "2005-05-01T10:22:12Z")
I don’t know if this exactly matches what you were looking for, but using British law databases, I found two verdicts that might be interesting because they address issues similar to the one you mention: One is R v Reynolds, Court of Appeal 1988. The appellant had been found guilty of murder, and teh Court of Appeal set this aside and found her guilty of manslaughter. Quote from the verdict: > [@](#): > > Dr D… was therefore putting forward her opinion before the court that this was a case of diminished responsibility, the cause of that being a conjunction of premenstrual syndrome and postnatal depression. She stated in that report that what has been referred to as SHBG levels (that is sex hormone binding globule estimation) are required before it can be said with certainty whether there was premenstrual tension or not. The necessary clinical tests of SHBG were carried out whilst the appellant was in prison after conviction and they were positive, thus confirming Dr Dalton’s views of the existence of premenstrual tension. Needless to say, those clinical results could not have been adduced at the trial because they were not carried out untul after the trial was over. The other one is again Court of Appeal, R v Beer 1985, a rather petty shoplifting case. Quote: > [@](#): > > The fact of the matter is that having heard all the evidence the jury convicted. That evidence included medical evidence to the effect that in all probability this appellant was suffering from premenstrual syndrome at the time that this offence was committed and that had its effect upon her, but, having regard to the verdict of the jury, not such an effect as to prevent her from knowing precisely what she was doing and that she was doing it dishonestly. This sounds as if the court might have accepted premenstrual syndromes as reducing responsibility if severe enough. Hope that helps. ---
**Author:** ![Gfactor](https://avatars.discourse-cdn.com/v4/letter/g/9de053/32.png) [@Gfactor](https://boards.straightdope.com/u/Gfactor)\ **Post date:** [May 1, 2005, 5:53pm UTC](https://boards.straightdope.com/t/is-there-a-legal-precedent-accepting-pmdd-for-not-guilty-by-reason-of-insanity-plea/301746/3 "2005-05-01T17:53:25Z")
[Aricle discussing PMS defense in UK](http://www.aic.gov.au/publications/proceedings/16/Easteal2.pdf) And see [this](http://www.straightdope.com/mailbag/mdimcapacity.html) on the difference between dimished capacity and insanity as defenses. It seems like it has worked a couple of times as the basis for a diminished capacity defense. [Another article collecting cases and discussing the use of the defense.](http://www.jagcnet.army.mil/JAGCNETINTERNET/HOMEPAGES/AC/ARMYLAWYER.NSF/0/19ca045891d7d0bf85256e5b0054db46/%24FILE/Article%202.pdf)