Terry Lenamon on the Death Penalty : Lawyer & Attorney Terry Lenamon on Capital Punishment Defense, Death Penalty Trials & Appeals | Law Firm

New York Times columnist Adam Liptak once again does us all a great service by bringing the national media spotlight to bear upon the crisis facing Cory R. Maples, who sets today on Alabama's Death Row. 

Sullivan & Cromwell Missed the Deadline to Appeal

Maples' case currently awaits the determination of the United States Supreme Court.  The High Court must decide the fate of Cory Maples, who relied upon the well-known law firm Sullivan & Cromwell to represent his interests -- only to have the deadline pass for him to file an appeal. 

That's right:  elite Sullivan & Cromwell representation and a basic, basic deadline was blown. 

What the Heck Happened?

As Liptak explains, the Big Firm did not place its firm name within the signature block of the two associates that were on the record as being Maples' defense counsel.  Nevermind the question of whether or not these two were death qualified, had any past criminal defense experience, etc.  We don't get there (yet). 

Apparently, Sullivan & Cromwell felt it would be bad public relations to represent a man facing death at the hands of the State of Alabama so shame (and that's the core issue here, let's not beat around the bush) kept the firm name off the mailing list.  Which wasn't such a big deal until the two lawyers left the firm.

Did Sullivan & Cromwell forward the mail addressed to the two associates to their new mailing address?  No.  They sent the notices back to the court.  That's right: the court.

Return to Sender

Sullivan & Cromwell returned the court's correspondence back to the court itself.  As the New York Times reports, there were TWO envelopes sent back to the court clerk. 

One was marked “Return to Sender — Left Firm” handwritten across the front and just to make sure, it was also stamped “Return to Sender — Attempted Not Known.” The second piece of court correspondence was stamped “Return to Sender — Attempted Unknown,” without any added handwritten message.

Curious by its absence, any reference to the forwarding addresses of the two lawyers who had left the firm.  Surely the law firm knew them.  Surely the State Bar website could provide them.  Apparently, the Sullivan & Cromwell perspective was that the court could figure it out -- it wasn't Sullivan & Cromwell's problem.

Except it was.  And it is.  Because the representation of Cory Maples didn't leave with the two associates -- it was merely reassigned to two other firm lawyers. Who knew zip about what was happening until Cory's mother called to check on the status of the appeal.

What Did Sullivan & Cromwell Do Next?

Swanky Sullivan & Cromwell went before the Atlanta federal appeals court on behalf of Cory Maples.  And lost.   Now, the firm has seen fit to bring in a former United States solicitor general, Gregory G. Garre, to argue on behalf of Mr. Maples before the United States Supreme Court.  And, indirectly of course, he's arguing for Sullivan & Cromwell at this point. 

His big argument to the High Court on why they should grant his petition?  That Cory Maples should not be responsible for his lawyer's mistake. 

However, the federal precedent is filled with clients that do get left holding the bag for their lawyer's mistakes - limitations are passed, deadlines are missed, and the law usually says that the client's remedy is to sue the law firm for malpractice.  Except that Cory Maples can't get his life back from Sullivan & Cromwell.  Sullivan & Cromwell's mail room glitch might well cost Mr. Maples his life. 

Another Lesson in the Crisis of Indigent Defense of Death Penalty Defendants

Why was an elite New York law firm appointed to represent an indigent criminal defendant?  The New York Times reports that the trial lawyers actually told the jury during the penalty phase that they weren't experienced here, and warned the jurors they “may appear to be stumbling around in the dark.” Result?  The jury came back in favor of the death penalty, with a vote of 10 to 2.

It's all about money.  Alabama doesn't budget for indigent appellate defense for those on death row.  Alabama lets elite firms take these cases on pro bono, and they don't even have to be within the state lines: elite firms like Sullivan & Cromwell.   

The reality is that the error that may cost Cory Maples his life isn't just the fault of Sullivan & Cromwell.  It's the responsibility of all who fail to acknowledge and provide for adequate funding for qualified, experienced indigent defense representation in capital punishment cases. 

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California attorney Brad Levenson, a federal public defender, was revealed this week to be the new head of a brand new agency over in Texas: the Office of Capital Writs.  Levenson starts work on September 1st.

Texas' Office of Capital Writs is an Attempt to Solve the Indigent Defense Crisis - In Part

In 2009, the Texas Legislature created (and by that we mean, of course, set aside money in the budget) for the Office of Capital Writs after things became obvious that the indigent defense being provided appealing defendants convicted of capital crimes was ludicrous. 

Studies were done.  Newspapers like the Dallas Morning News regularly reported on the horrors of death penalty indigent defense in Texas today.  The Texas Legislature reacted. 

Light was shed on some pretty shocking scenarios:  death penalty defendants with appellate lawyers having no death penalty defense experience; some having attorneys who had walked away from the appeal/appointment; others having appellate counsel who had died and were never replaced with a new court appointment.  Appalling in any state, but especially in Texas where capital punishment is so favored.  

The Office of Capital Writs Replaces Court Appointed Appeals Counsel in Death Penalty Cases

Starting this fall, Brad Levenson will be responsible for representing Texas Death Row appellants in state habeas corpus appeals. Proponents argue that this solution will not only provide a higher quality of appellate counsel for those setting on Death Row, but it will cost about the same. 

Believers are also arguing that Texas' OCW will result in lower caseloads and higher accountability in indigent capital defense appeals. 

This Should Be Interesting ....

One wonders how a man with federal experience in another state -- especially California, whose liberal approach to the death penalty in its precedent is almost in direct contrast to the perspective given capital punishment in Texas courts -- was determined to be the best fit for this new job.  Interesting.

Also, there's the idea of costs.  One of the core problems with indigent defense is a lack of funds.  The reason behind those court appointments being downright embarrassing for the State of Texas is the reality that there wasn't enough funding to pay more experienced or higher quality private appellate attorneys sufficiently to take those Death Penalty appeals. 

It's a core problem across this country - money for indigent defense.  So, while we all support this new tactic to provide decent appellate representation to defendants who set on Texas Death Row, it's going to be interesting to watch how the Texas Office of Capital Writs will be doing in the next few years.

Best of luck to Mr. Levenson.  We will watch and pray.

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Georgia Defendant Jamie R. Weis is getting lots of media attention today, as an article written by Adam Liptak in yesterday's New York Time's Sidebar column is being republished and discussed all over the country. 

What NYT's Liptak has done is place a spotlight upon a case that has been pending before the U.S. Supreme Court for awhile now.  In Cause No. 09-10715, Jamie R. Weis is petitioning the HIgh Court to review a decision of the Georgia Supreme Court, which voted its 4-3 approval of state prosecutors to seek the death penalty against Mr. Weis -- even though he has been incarcerated for two years without an attorney.  (Read the Petition for Writ of Certiorari here.)

That's right. Jailed. No lawyer. Two years. Georgia. Death Penalty Sought.

Mr. Weis's petition is based in part on an argument that he has been denied his right to a speedy trial. (A criminal defendant's right to a speedy trial is guaranteed to him/her under the Sixth Amendment, as well as various statutes such as the federal Speedy Trial Act.) 

Indigent Defense Crisis in Death Penalty Cases: Real Issue Before the U.S. Supreme Court in Weis

However, if you're wondering about money being the reason behind all of this, you're right.  Like many death penalty defendants, Mr. Weis cannot afford to hire his own counsel.  Apparently, the State of Georgia has not been able to find the funds to pay for an attorney to represent him. 

Powerful Amicus Brief Brings Capital Defense Indigent Defense Crisis Into Focus

In an amicus curaie brief filed last month, several prominent members of the GeorgiaBar presented their arguments to the Supreme Court, in support of Weis' petition.  Among them: Norman Fletcher, former Chief Justice of the Georgia Supreme Court.  (Read their amicus brief here.)

Tellingly, and importantly, the friends of the court argue that the Georgia state legislature made a "deliberate choice to not adequately fund indigent defense" -- and accordingly, defendants should not suffer -- and have their constitutional rights ignored -- because of a lack of funding.

New York Times Article Helps Bring Public Awareness to Critical Issue

In the court of public opinion, Adam Liptak dovetails the amicus brief's overview of the current state of indigent defense within the State of Georgia with a discussion of the right to appointed counsel.  Liptak includes the recent decision by the U.S. Supreme Court in Vermont v. Brillon, where they recognized the possiblity of “a systemic breakdown in the public defender system,” but failed to give any solutions to that situation.

Crisis in Death Penalty Indigent Defense Funding Must Be Addressed

One of the recurring themes of this blog is the crisis facing the criminal justice system today, in every state, because of the lack of funding for indigent defense.  Will the High Court finally address the practical realities of implementing the constitutional rights it has recognized with the correlated budgetary commitments it has created? 

Let's watch and see.  Fingers crossed? Yes.  Don't hold your breath, though.

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Before I begin to get queries on the recent departure of Andrea Lyons from the Casey Anthony Defense Team (since both Ms. Lyon and I served as death penalty qualified counsel for Casey Anthony at one point), I ask that anyone interested read the quote that I gave to Anthony Colarossi of the Orlando Sentinel:

http://www.orlandosentinel.com/news/local/caylee-anthony/os-casey-anthony-andrea-lyon-20100630,0,2682343.story

 Thanks to all.

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There's a new judge in the Casey Anthony case -- Judge Belvin Perry -- and he looks to be running a tight ship.  Despite defense counsel requests that hearings on defense costs be private, Judge Perry has ordered that an upcoming hearing on how Casey Anthony's defense will be funded is to be a public hearing.

May 6, 2010, Hearing on Indigent Defense Costs for Casey Anthony Will Be Public

That's right:  anyone interested in hearing the details on how the defense of Casey Anthony in the trial of whether or not she murdered her daughter, and whether or not the State of Florida should execute her for that crime (if found guilty) will be PUBLIC. 

Which, given the media coverage of the Casey Anthony case, means there will be countless news reports giving the financial details of this death penalty defense.

What Is Expected to Happen at the Casey Anthony Budget Hearing

At Thursday's budget hearing, Judge Perry expects to hear an estimate from the defense team on the number of hours their experts will need.  The Judge has also stated that he will want to know if the experts are willing to work under the fee schedule set by Florida's Justice Administrative Commission.  (Read the Scheduling Order here.)

The public will soon glimpse into the practicalities of defending someone who's facing the death penalty in Florida.  Experts -- and their hourly rates -- will be revealed, and discussed from a budgetary standpoint. 

The JAC Fee Schedule Will Be Discussed - Hopefully, Part of the Indigent Defense Crisis Will Be Seen

The JAC fee schedule will be a subject of discussion, too.  Perhaps Judge Perry should review JAC v. Lenamon before the hearing on Thursday -- because the JAC has proven itself all too willing to appeal the decisions of trial judges that seek to be fair and reasonable in this area. 

The experts needed for both the guilt phase and the penalty phase of any death penalty defense case are varied in their special knowledge and expertise and far from inexpensive due to their education and experience.  Their standard hourly rates will not jive with the JAC schedule. 

With the hearing on May 6th, hopefully more people will become aware of the practical realities of indigent defense representation Florida and elsewhere.  Will the experts work for less than their standard rate?  How low does the State of Florida (through the JAC) expect doctors, psychiatrists, forensic specialists, etc., to charge?   Hopefully, the public will see some of these questions answered this week. 

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As predicted, coverage is increasing on the impeding June 2010 firing squad execution of Utah's condemned man, Ronnie Lee Gardner.  The idea that a man will die by bullets instead of injected poison is shocking many - and there's already chatter about a firing squad being unconstitutionally cruel.

Appeal Points to the Elephant in the Room: Insufficient Funding for Proper Death Row Defense 

Ronnie Lee Gardner's appeal is of great interest to death penalty defense lawyers all across this country.  Why? 

Because Gardner's appellate attorneys are arguing error exists because Gardner was not provided adequate money by the State of Utah so he could get the necessary experts and investigators he needed to prove up mitigating factors during the punishment phase of his trial.

In other words, if Utah had provided sufficient defense funding to allow Gardner's defense counsel to hire psychologists, private investigators, etc. to establish circumtances that countered against the imposition of the death penalty, then Gardner wouldn't be in a position to choose death by firing squad now. 

Motion for Stay of June 18, 2010 Firing Squad Execution Awaits Ruling

Gardner's counsel has filed a motion to stay the Order of District Judge Robin Reese, who ordered that 49 year old Ronnie Lee Gardner will be executed by firing squad on June 18, 2010.  This request is in tandem with the emergency appeal filed with the Utah Supreme Court on the indigent defense bases. 

Will the Firing Squad Coverage Bring Attention to the Indigent Defense Funding Crisis?

The lack of adequate funding for indigent defense - especially in capital punishment cases - is a growing crisis in Florida and across the country.  Since it deals with budget concerns and financial analysis, the topic doesn't get the kind of coverage that other issues do -- but maybe Gardner's case will change things. 

Maybe the firing squad aspect of his story will allow the indigent defense funding issue to dovetail itself into the next few weeks of coverage (assumed to be escalating as June 18th nears).  Let's watch and see....

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(For details on this issue, please read the longer article at our JDSupra repository.)

 JAC gets national recognition in the Casey Anthony case

Florida’s Justice Administrative Commission received a significant amount of media coverage recently when it became involved in the Casey Anthony case, providing the trial court judge with the official JAC position on whether or not Casey Anthony should be confirmed as “indigent” under the law.

The JAC was leery of Anthony's claims that she was unable to pay for legal counsel, and hearings were held as well as in-camera considerations by the judge.  Casey Anthony was declared indigent by Judge Stan Strickland on March 19, 2010.

What is the JAC?

In 1965, the Judicial Administrative Commission was formed by the Florida Legislature with representatives from the state judicial branch acting as commissioners, i.e., offices of the state attorney and the public defender; the district, circuit, and appellate courts; and of course, the Florida Supreme Court, acting through its Chief Justice (or his designee). Over the years, the commission evolved. There has been a name change: it is now the Justice Administrative Commission. Today, it is comprised of four members, none of whom are judges: two state attorneys and two public defenders. 

And, it’s got lots and lots of power over when and how attorneys are paid for defending the indigent in this state. 

Lenamon and the Justice Adminstrative Commission - the Background of JAC v. Lenamon

In a double homicide, death penalty case involving nine (9) defendants, seven defendants were left with the circuit court judge needing appointed, private criminal defense lawyers as their attorneys due to conflicts with the available public defenders. 

 There were not enough death-penalty qualified defense attorneys within the 20^th District, so the judge was forced to look elsewhere, finding the name “Terence Lenamon” on the death-penalty qualified list for the Eleventh Judicial District.   Lenamon was appointed. 

The JAC Contracts

The JAC enters into representation agreements on a district-by-district basis. Here, the JAC had no option but to enter into a new contract -- specific to this single representation – with any and all out of district defense attorneys appointed by the trial judge to advocate for clients facing the death penalty in his Lee County courtroom.  So, the JAC and Lenamon entered into a brand new deal.

JAC v. Lenamon – JAC fights the Defense Lawyer

When Lenamon’s first invoice was submitted to the trial court judge, it was approved. When the JAC asked the judge to reconsider, he did. And he didn’t change his mind. When the JAC appealed his ruling to the appellate court, here was that court's telling language (Opinion, p. 5, fn. 3) (emphasis added):

Mr. Lenamon also argues that the $125 per hour rate was fair and reasonable in light of the exceptional circumstances present in this case. We do not doubt that the $125 per hour rate approved in the circuit court's order is fair and reasonable. However, the question before us is whether payment at a rate exceeding $100 per hour is authorized by law, not whether it is fair and reasonable.

What’s the Lesson of JAC v. Lenamon?

One lesson: Experienced criminal defense attorneys may not be very welcoming of appointments in other judicial districts after reading Justice Administrative Commission v. Lenamon. This is particularly true when these criminal defense attorneys already know they'll be paid a much lower hourly rate than any Florida legal market rate as a court-appointed counsel.   Mercenary hearts don't take court appointed death penalty cases. 

Another: While the JAC is trying to pinch every penny in its budget, the JAC is not recognizing the burdensomeness of forcing an out-of-district attorney to travel to outside his or her practice area to meet a county’s need for a lawyer at their level of expertise. 

In a time when defense attorneys are desperately needed to fill the need imposed by the constitutional right to counsel for the indigent, especially those who are death-penalty qualified, the JAC seems blind to the fact that it is alienating the very resource that is in scant supply. 

Third: The system needs work, when the reality is that a JAC fee fight like this one places the defense attorney in the position of fighting the State of Florida in one courtroom on behalf of his client, and then fighting the State of Florida down the hall, just to try and keep them from cutting his fees for doing his job in the first courtroom.  

There’s a lot wrong here that needs to be fixed. 

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You have to read this book. 

That's all I really need to write here, but it's impossible to stop typing about how David Dow's memoir is so important for anyone connected with capital punishment to read -- and why this is so.

First, he provides a clear and unique perspective.  David Dow is not only a professor at the University of Houston Law Center, he's also the head of litigation at the Texas Defender Service.   Professor Dow has been in the trenches of death penalty defense for years, and knows of what he speaks. 

Second, he's writing a memoir this time.  Professor Dow has been published before, but his previous works were more analytical in nature.  Works like Machinery of Death: The Reality of America's Death Penalty Regime (Taylor & Francis 2002), and Executed on a Technicality (Beacon 2005).  This book gives an inside view of what it's like to represent clients who are facing death by execution.  Intersecting in these pages are Dow's dealings with his young son and how appellate demands (particularly in death penalty cases) collide with family time and parenting needs.  It's something that all capital litigators can truly understand, and it's rare that someone reveals the razor's edge we sometimes walk.

Third, Professor Dow gives us reality that is perhaps easier revealed via this personal perspective.  In Anatomy of an Execution, David Dow doesn't pull any punches.  He's showing you the underbelly of capital punishment in this country today, from the standpoint of an expert defense counsel.  From the book, you find out things such as:

1. There was a time that he was in favor of capital punishment.  He understands the arguments of death penalty proponents. 
2. Sometimes, he's hasn't liked his client -- and it's brave of him to admit this.  Of course, that hasn't stopped his calling to stand against a client's execution. 
3. Money -- and budgeting -- are just as much a concern of the defense as it is for the prosecution.  David Dow's story, covering a select number of representations as they dovetailed with his personal life, actually brings home the financial realities of capital punishment defense in this country:  Administrative matters and an analysis of cost vs benefit do happen in death penalty cases, and hat's off to Professor Dow for shedding some light on the elephant in the room. 

 For more, check out a post written by David Dow, discussing how he came to write this book, over at the Huffington Post. 

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This past week, the film Capote (2005) was shown on television -- and while the name suggests that the movie covers the life of famed author Truman Capote, that's not the case.  What the movie focuses upon is Capote's involvement with two men who were executed by the  State of Kansas for the killings of the Clutter family in Holcomb, Kansas back in the late 1950s.

For those - like me - who are interested in how the death penalty is presented to America not only in the media and in our legislation but in our popular culture, I found the movie to be important. 

Not only does it provide an excellent perspective on how the trial and appellate process can cover years and years as the case winds its way through both the state and federal systems, but it reveals so much about the prisoners themselves.  How they spend years and years in small cells, a punishment in and of itself -- and in Perry Smith's case, the movies also gives food for thought about how a small boy could grow up to end his life by a hangman's noose.

And the execution of Perry Smith is shown in Capote.  In the 1960s, Kansas still executed prisoners by hanging.  You see the entirety of the process, and for those who wonder about those last moments - the film strives for accuracy.  There is the harness, there is the hood placed over the prisoner's head (for the benefit of the witnesses many argue, as opposed to the condemned), there is the sound of the latch being thrown and the body falling down, swaying in the open air. 

It's a memorable scene in a memorable film. 

And, as for hanging as a form of capital punishment, we don't see that today.  Today, only two states still allow for hanging and then, only as an option the lethal injection.  (That's Delaware and Washington.) 

Why not?  Hanging someone to kill them is tricky business.  If the state doesn't do its math right, calculating the weight of the individual and comparing it against the length of the drop and the strength of the rope, then the condemned does not die by a swift break of the neck but instead slowly suffocates -- which is said to be a very messy and painful process. 

In Capote (2005), the execution goes smoothly and Truman Capote (played by Philip Seymour Hoffman) watches without a word and then walks away.  Afterwards, he completes In Cold Blood -- a telling of the Clutter killings, the investigation and arrest of Perry Smith and Richard Hickock, following the judicial process through their deaths.   

And, of course, In Cold Blood is a must read for those dealing with the issue of capital punishment in this country -- and watching Capote, as this important book is being created, makes you want to pull that important book off the shelf and re-read it.  Which I, for one, am going to do.

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Justice Raoul Cantero III knows his stuff: he's served as a justice on the Florida Supreme Court. So does Mark Schlakman, who has been a senior program director at the Center for the Advancement of Human Rights at Florida State University. When these two team up to write an opinion piece, you betcha I'm gonna read it -- and hopefully a lot of other people will, too.

Cantero and Schlakman are Blunt: the Current Florida Death Penalty System is "FRAUGHT WITH PROBLEMS"

Essentially, these two experts in the field have taken the American Bar Association report that analyzed the state of Florida's death penalty system as it stood three years ago, and they've compared it to the realities of the system today.  It wasn't a namby-pamby report:  the ABA put together a team of the highest quality experts in the field, and financed their TWO YEAR study of the Florida system.  Surely some of what they recommended (and their recommendations had to be unanimous to be included) would be respected and implemented, right?  Nope.

Florida fails in the comparison. 

According to their op-ed piece, Cantero and Schlakman discovered that neither the Florida Bar Association nor the State of Florida have done much of anything in response to the ABA's report.  Nada, really.  Meanwhile, since 1973, they note that Florida has exonerated more Death Row inmates than any other state.

 The op-ed itself is R. Cantero & M. Schlakman, "State's death penalty system still 'fraught with problems,'" Florida Times-Union, Sept. 25, 2009 (op-ed), 

Here are some highlights: 

"Among the report's findings was that legal representation of death penalty defendants in postconviction proceedings is often abysmal."

"...called upon the Legislature to revisit the death penalty statute."

"The report also expresses concern about socioeconomic and geographic bias. Prosecutors from one circuit might opt for the death penalty while prosecutors from another might opt for life without parole."

"Circuit judges, who preside over capital cases, while nonpartisan and subject to the judicial canons, are not completely immune from such dynamics, since they also face the voters periodically."

Please read this opinion piece and share it with others.  It's important. 

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TruTV has published a collection of the last words uttered by those executed in various states across this country, just before they died. And while some may feel that these efforts of TruTV are sensational tabloid marketing, ghoulish and crass -- there is another argument to be made.

All too often, those living on Death Row are dehumanized. Perhaps dehumanizing here is a simple, human response to a situation where that individual is subject to death at the hands of the government - and therefore, at some level, by you and me. (We the people and all....)

However, when you read the words that these folk have said -- just minutes before they meet their Maker -- you get a good idea of who they were as people....

Some of them loved their families, and reached out to give them comfort.
Some asked for forgiveness, some spoke of the Lord.
A few said little at all.
Some of them seem bright, some of them seem dull.
Some took responsibility for their crimes, and some did not.

Photographs accompany the collection of statements. It's a site that is definitely worth your time to visit.

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Once again, I am honored to be a guest on Issues with Jane Velez Mitchell tonight, where the topic will be Andrea Lyon's request to the court that any ruling regarding the release of a video made of Casey Anthony being informed that a body had been discovered (which later was identified as that of her daughter Caylee) be delayed -- so that the defense can have time to investigate media leaks by the State.

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Later this month, a new reality-TV show will begin to air on the Discovery channel, called "Dallas DNA." Dallas County District Attorney Craig Watkins is supportive of this new show; he's quoted in USA Today as saying it " '...makes justice better by showing the good, the bad and the ugly.' " Meanwhile, the chief counsel to the Innocence Project of Texas, Jeff Blackburn, is quoted as believing that the show exists merely to boost Watkins' political career.

What is "Dallas DNA"?

The show itself focuses upon the use of DNA testing to discover individuals wrongfully convicted, particularly those on death row. Law students working with the Innocence Project of Texas, and presumably those working with District Attorney Watkins, will be the series' new reality stars. Their work will be filmed and televised for a profit.

Remember, this is a reality TV show. As is "Survivor," "Amazing Race," and "Dancing With the Stars."

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Last week, I wrote about mercy as being a lesson in the Casey Anthony case coverage. Here's another one that I'm pondering. Filicide. It's been around for centuries, it happens with alarming frequency in the United States today, and yet it is still one of those elephants in the room that no one wants to talk about.

Filicide? What's that?

Filicide is Susan Smith and Andrea Yates and Ellen Feinberg and Diane Downs. Filicide - maternal filicide -- is the name given to the particular kind of homicide where mothers kill their children. (Paternal filicide happens too, and more on that, later.)

You know about maternal filicide.

1. Meryl Streep won an Oscar for Sophie's Choice. What was that choice? Filicide.
2. Oprah Winfrey produced and starred in Beloved, based upon the novel by Toni Morrison, where the character Sethe killed her daughter Beloved to keep her from being a slave.
3. Medea (remember, Euripides?) killed her children all because Jason left her.
4. Lois (with Peter) killed son Stevie on an episode of TV's Family Guy.

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