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On 26 October 2006, the Appeal Court overturned the High Court's earlier ruling, allowing [[expert witness]]es to be disciplined once again but ruled that the High Court decision that Meadow was not guilty of serious professional misconduct should stand. However, on the issue of serious professional misconduct, the Appeal Court panel was split 2:1 with the dissenting senior judge, Sir [[Tony Clarke, Baron Clarke of Stone-cum-Ebony|Anthony Clarke]], concluding Meadow was "guilty of serious professional misconduct" and provided detailed reasons for his conclusion. One of the other two judges, [[Robin Auld|Lord Justice Auld]], said Meadow "was undoubtedly guilty of some professional misconduct" but that it "fell far short of serious professional misconduct".{{cn}}
On 26 October 2006, the Appeal Court overturned the High Court's earlier ruling, allowing [[expert witness]]es to be disciplined once again but ruled that the High Court decision that Meadow was not guilty of serious professional misconduct should stand. However, on the issue of serious professional misconduct, the Appeal Court panel was split 2:1 with the dissenting senior judge, Sir [[Tony Clarke, Baron Clarke of Stone-cum-Ebony|Anthony Clarke]], concluding Meadow was "guilty of serious professional misconduct" and provided detailed reasons for his conclusion. One of the other two judges, [[Robin Auld|Lord Justice Auld]], said Meadow "was undoubtedly guilty of some professional misconduct" but that it "fell far short of serious professional misconduct".{{cn}}


In 2004, Meadow’s ex-wife, Gillian Paterson, accused Meadow of seeing "mothers with Munchausen's Syndrome by Proxy wherever he looked," and implied that he was a [[misogynist]]: "I don't think he likes women... although I can't go into details, I'm sure he has a serious problem with women".<ref name="David Cohen"/>
In 2004, Meadow’s ex-wife, Gillian Paterson, accused Meadow of seeing "mothers with Munchausen's Syndrome by Proxy wherever he looked," and implied that he was a [[misogynist]]: "I don't think he likes women... although I can't go into details, I'm sure he has a serious problem with women".<ref name="David Cohen"/>{{better source needed|reason=Clearly an unreliable site}}


In 2009, Meadow relinquished his registration with the GMC and thus became unlicensed to practice medicine. In addition this voluntary erasure from the list of registered medical practitioners meant that he would no longer be answerable to the GMC should any further concerns be raised regarding any previous professional activity.<ref>{{Cite web |last=Blakemore-Brown |first=Lisa |title=Sir Roy Meadow removes himself from the General Medical Council Register |url=http://www.theoneclickgroup.co.uk/news.php?id=4111#newspost |archive-url=https://web.archive.org/web/20150205173733/http://www.theoneclickgroup.co.uk/news.php?id=4111#newspost |archive-date=5 February 2015}}</ref>
In 2009, Meadow relinquished his registration with the GMC and thus became unlicensed to practice medicine. In addition this voluntary erasure from the list of registered medical practitioners meant that he would no longer be answerable to the GMC should any further concerns be raised regarding any previous professional activity.<ref>{{Cite web |last=Blakemore-Brown |first=Lisa |title=Sir Roy Meadow removes himself from the General Medical Council Register |url=http://www.theoneclickgroup.co.uk/news.php?id=4111#newspost |archive-url=https://web.archive.org/web/20150205173733/http://www.theoneclickgroup.co.uk/news.php?id=4111#newspost |archive-date=5 February 2015}}</ref>

Revision as of 17:04, 15 March 2024

Sir
Samuel Roy Meadow
Born (1933-06-09) 9 June 1933 (age 91)
Wigan, Lancashire, England
OccupationPaediatrician
Known forWrongful convictions of mothers for murdering their babies
Meadow's law

Sir Samuel Roy Meadow (born 9 June 1933)[1] is a British retired paediatrician infamous for facilitating several wrongful convictions of mothers for murdering their babies. He was awarded the Donald Paterson prize of the British Paediatric Association in 1968 for a study of the effects on parents of having a child in hospital. In 1977, he published an academic paper describing a phenomenon dubbed Munchausen Syndrome by Proxy (MSbP). In 1980 he was awarded a professorial chair in paediatrics at St James's University Hospital, Leeds, and in 1998, he was knighted for services to child health.[2]

His work became controversial, particularly arising from the consequences of a belief he stated in his 1997 book ABC of Child Abuse that, in a single family, "one sudden infant death is a tragedy, two is suspicious and three is murder, until proved otherwise".[3] This became known as "Meadow's law" and was influential in the thinking of UK social workers and child protection agencies, such as the National Society for the Prevention of Cruelty to Children.[4]

Meadow's reputation was severely damaged after his appearances as an expert witness for the prosecution in several trials played a crucial part in wrongful convictions for murder. Despite having fundamental misunderstandings of statistics he presented himself as an expert in the field. Meadow's miscalculations significantly contributed towards the wrongful imprisonment of innocent mothers whom he branded murderers. The British General Medical Council (GMC) struck him from the British Medical Register after he was found to have offered erroneous and misleading evidence in the 1999 trial of Sally Clark, who was wrongly convicted of the murder of her two baby sons.[5][6] Clark's conviction was overturned in 2003 but she never recovered from the experience, and died in 2007 from acute alcohol poisoning.[7]

Clark's father, Frank Lockyer, complained to the GMC, alleging serious professional misconduct on the part of Meadow. The GMC concluded in July 2005 that Meadow was guilty, but he appealed to the High Court, which in February 2006 ruled in his favour. The GMC appealed to the Court of Appeal, but in October 2006, by a majority decision, the court upheld the ruling that Meadow was not guilty of the GMC's charge. The reason was that his behaviour in court did not impact his care for his own patients.[8]

Early career

Meadow was born in Wigan, Lancashire, the son of Samuel and Doris Meadow. He studied medicine at Worcester College, Oxford, and later practised as a GP in Banbury, Oxfordshire.[when?] Throughout his early years in medicine, Meadow was a devoted admirer of Anna Freud (daughter of Sigmund Freud), whose lectures he would often attend. Speaking in later life, he said: "I was, as a junior, brought up by Anna Freud, who was a great figure in child psychology, and I used to sit at her feet at Maresfield Gardens in Hampstead. She used to teach us that a child needs mothering and not a mother."[9] There is some controversy over these claims. According to the London Evening Standard, representatives of the Anna Freud Centre claimed to have no record of him completing a formal training there and repudiated his description of her philosophy.[9]

Meadow was appointed professor of paediatrics and child health at the University of Leeds in 1980, based at St James's University Hospital, having previously been a Senior Lecturer in the same department.[10] He retired with the title Emeritus Professor in 1998.[11]

In 1961, Meadow married Gillian Maclennan, daughter of Sir Ian Maclennan, the British ambassador to Ireland. The couple had two children, Julian and Anna, before divorcing in 1974. Four years later he married his second wife, Marianne Jane Harvey.[citation needed]

Munchausen Syndrome by Proxy

In 1977, in The Lancet medical journal, Meadow published the theory which was to make him famous.[12] Sufferers of his postulated Munchausen Syndrome by Proxy or MSbP (a name coined by Meadow himself) harm or fake symptoms of illness in persons under their care (usually their own children) in order to gain the attention and sympathy of medical personnel. This claim was based upon the extraordinary behaviour of two mothers: one had (Meadow claimed) poisoned her toddler with excessive quantities of salt. The other had introduced her own blood into her baby's urine sample. Although it was initially regarded with scepticism, MSbP soon gained a following amongst doctors and social workers.

Expert testimony

Main article: Meadow's law

In 1993, Meadow gave expert testimony at the trial of Beverley Allitt, a paediatric nurse accused (and later found guilty) of murdering several of her patients.[13]

Meadow went on to testify in many other trials, many of which concerned cases previously diagnosed as cot death or sudden infant death syndrome (SIDS). Meadow was convinced that many apparent cot deaths were the result of physical abuse. Families that had suffered more than one cot death were to attract particular attention: "There is no evidence that cot deaths runs in families", said Meadow, "but there is plenty of evidence that child abuse does". His rule of thumb was that "unless proven otherwise, one cot death is tragic, two is suspicious and three is murder".[14]

Although this dictum is believed not to have originated from Meadow's own lips, it has become almost universally known as Meadow's law.[citation needed]

Cot death trial controversies

This trend was to reach its apogee in 1999 when solicitor Sally Clark was tried for allegedly murdering her two babies. Her elder son Christopher had died at the age of 11 weeks, and her younger son Harry at 8 weeks. Medical opinion was divided on the cause of death, and several leading paediatricians testified that the deaths were probably natural. Experts acting for the prosecution initially diagnosed that the babies had been shaken to death, but three days before the trial began several of them changed their collective opinion to smothering.

By the time he gave evidence at Sally Clark's trial, Meadow claimed to have found 81 cot deaths which were in fact murder, but he had destroyed the data.[15] Amongst the prosecution team was Meadow, whose evidence included a soundbite which was to provoke much argument: he testified that the odds against two cot deaths occurring in the same family was 73,000,000:1, a figure which he erroneously obtained by squaring the observed ratio of live-births to cot deaths in affluent non-smoking families (approximately 8,500:1). In addition he extrapolated his erroneous figures stating that the 1 in 73,000,000 incidence was only likely to occur once every hundred years in England, Scotland and Wales. He further illustrated his miscalculation by stating that the very unlikely odds were the same as successfully backing to win an 80/1 outsider in the Grand National for four successive years.[16] The jury returned a 10/2 majority verdict of "guilty".

Misuse of statistics

Meadow's 73,000,000:1 statistic was paraded in the popular press[17][18] and received criticism from professional statisticians over its calculation. The Royal Statistical Society issued a press release stating that the figure had "no statistical basis", and that the case was "one example of a medical expert witness making a serious statistical error."[19] The Society's president, Professor Peter Green, later wrote an open letter of complaint to the Lord Chancellor about these concerns.[20]

The statistical criticisms were threefold: firstly, Meadow was accused of applying the so-called prosecutor's fallacy in which the probability of "cause given effect" (i.e. the true likelihood of a suspect's innocence) is confused with that of "effect given cause" (the probability that an innocent person would lose two children in this manner). In reality, these quantities can only be equated when the a priori likelihood of the alternative hypothesis, in this case murder, is close to certainty. Murder (especially double murder) is itself a rare event, whose probability must be weighed against that of the null hypothesis (natural death).[19]

The second criticism concerned the ecological fallacy: Meadow's calculation had assumed that the cot death probability within any single family was the same as the aggregate ratio of cot deaths to births for the entire affluent-non-smoking population. No account had been taken of conditions specific to individual families (such as the hypothesised cot death gene) which might make some more vulnerable than others.[21] Finally, Meadow assumed that SIDS cases within families were statistically independent. The occurrence of one cot death makes it likely that the family in question has such conditions, and the probability of subsequent deaths is therefore greater than the group average.[19] (Estimates are mostly in the region of 1:100.)

Some mathematicians have estimated that taking all these factors into account, the true odds may have been greater than 2:1 in favour of the death not being murder, and hence demonstrating Clark's innocence.[22]

The perils of allowing non-statisticians to present unsound statistical arguments were expressed in a British Medical Journal (BMJ) editorial by Stephen Watkins, Director of Public Health for Stockport, claiming that "defendants deserve the same protection as patients."[21]

Sally Clark appeals

See also: Sally Clark

Meadow's statistical figure was amongst the five grounds for appeal submitted to the Court of Appeal in the autumn of 2000. The judges claimed that the figure was a "sideshow", which would have had no significant effect on the jury's decision. The overall evidence was judged to be "overwhelming" and Clark's appeal against conviction was dismissed. This opinion, minimising the effect of Meadow's evidence, was described by a leading QC[who?] not involved in the case as "a breathtakingly intellectually dishonest judgement". Frank Ward, writing for Miscarriages of Justice UK, preferred the term "intellectually incompetent".[23][24]

Clark's supporters rejected this decision. Meadow considered that he had been fully vindicated. He responded to Watkins in a BMJ paper of his own,[25] accusing him of being both irresponsible and misinformed. He reiterated his erroneous claim that "both children showed signs of both recent and past abuse" (injuries which the defence claimed were either misidentified in a badly-performed post-mortem, or caused by the mother's attempts at resuscitation) and underlined the judges' controversial ruling that Clark and her husband had given "untrue evidence".[citation needed]

Meadow's vindication was to be short-lived: after the campaigning lawyer Marilyn Stowe obtained new evidence from Macclesfield Hospital, it emerged that another expert witness, Home Office Pathologist Dr Alan Williams,[26] had failed to disclose exculpatory evidence in the form of results of medical tests which showed that her second child had died from the bacterial infection Staphylococcus aureus, and not from smothering as the prosecution had claimed. A second appeal was launched and in allowing Clark's appeal to proceed Lord Justice Kay stated in open court that Meadow's statistics were 'grossly misleading' and 'manifestly wrong'.[27]

Although the central reasons for the Clark appeal's success were separate from Meadow's evidence, the discredited statistics were revisited in the hearing. In their ruling, in marked contrast to the opinions at the first appeal, the judges stated that:

"....if this matter had been fully argued before us we would, in all probability, have considered that the statistical evidence provided a quite distinct basis upon which the appeal had to be allowed."

Sally Clark's conviction was overturned in January 2003.[28]

Death of Sally Clark

Sally Clark died unintentionally on 16 March 2007 from acute alcohol intoxication.[29]

Her family said she "never fully recovered from the effects of this appalling miscarriage of justice".[30]

Aftermath

In January 2004, the Deputy Chief Justice, Lord Justice Judge, gave the full reasons for allowing Cannings' appeal. His comments included criticism of Meadow's evidence, of his standing as an expert witness and of 'experts' adopting an over-dogmatic stance :

"Therefore the flawed evidence he gave at Sally Clark's trial serves to undermine his high reputation and authority as a witness in the forensic process. It also, and not unimportantly for present purposes, demonstrates not only that in this particular field which we summarise as "cot deaths", even the most distinguished expert can be wrong, but also provides a salutary warning against the possible dangers of an over-dogmatic expert approach".[31]

Only a relatively small number of appeals were actually launched, though most of these were successful (including that of Donna Anthony, who served six years after being wrongly convicted of killing her son and daughter). In addition to this, the law was changed such that no person can be convicted on the basis of expert testimony alone.[citation needed]

On 21 June 2005, Meadow appeared before a GMC fitness to practise tribunal. On the first day of Meadow's defence, Dr Richard Horton, Editor of The Lancet, published an article in defence of Meadow.[32] This controversial interference in the GMC process 'incensed' Sally Clark.[33] Her husband, Stephen, later wrote to the Lancet to highlight Horton's "many inaccuracies and one-sided opinions" in order to prevent them prejudicing independent observers.[34][35][better source needed]

On 13 July, the tribunal ruled that his evidence in the Clark case was indeed misleading and incorrect and on 15 July decided he was guilty of "serious professional misconduct".[36]

It was during the hearing that, when questioned directly on the matter, Meadow made his first public apology for the effect of his 'misleading' evidence. He cited the reasons for the delay as being 'legal advice' and 'professional etiquette'.[37] The failure to apologise, and not admitting that he was wrong, was the reason why Sally Clark's father, Frank Lockyer, had raised his concerns about Meadow with the GMC.[38]

His failure to apologise spontaneously was not his first departure from good ethical conduct in this case; during a break at Clark's committal hearing at Macclesfield Magistrates' Court Meadow had approached the defence team and addressed Sally Clark saying, 'this is terrible for me, it must be awful for you.' He was instructed by Clark's barrister Michael Mackey to 'go away'.[39]

The decision was made that his name should be struck from the medical register. The Society of Expert Witnesses commented that the severity of this punishment would cause many professionals to reconsider whether to stand as expert witnesses.[40]

The following month, Meadow launched an appeal against this ruling. On 17 February 2006, High Court judge Mr Justice Collins found in his favour, ruling against the decision to strike him from the medical register. The judge stated that although the GMC had been right to criticize him, his actions could not properly be regarded as "serious professional misconduct".[citation needed]

On 26 October 2006, the Appeal Court overturned the High Court's earlier ruling, allowing expert witnesses to be disciplined once again but ruled that the High Court decision that Meadow was not guilty of serious professional misconduct should stand. However, on the issue of serious professional misconduct, the Appeal Court panel was split 2:1 with the dissenting senior judge, Sir Anthony Clarke, concluding Meadow was "guilty of serious professional misconduct" and provided detailed reasons for his conclusion. One of the other two judges, Lord Justice Auld, said Meadow "was undoubtedly guilty of some professional misconduct" but that it "fell far short of serious professional misconduct".[citation needed]

In 2004, Meadow’s ex-wife, Gillian Paterson, accused Meadow of seeing "mothers with Munchausen's Syndrome by Proxy wherever he looked," and implied that he was a misogynist: "I don't think he likes women... although I can't go into details, I'm sure he has a serious problem with women".[9][better source needed]

In 2009, Meadow relinquished his registration with the GMC and thus became unlicensed to practice medicine. In addition this voluntary erasure from the list of registered medical practitioners meant that he would no longer be answerable to the GMC should any further concerns be raised regarding any previous professional activity.[41]

Ian and Angela Gay

In the 2005 trial of Ian and Angela Gay over the death of their adopted son Christian, the prosecution relied heavily upon Meadow's 1993 paper "Non-accidental salt poisoning",[42] citing it many times throughout the trial. The judge also referred to the paper citing it five times during his summing up. Ian and Angela Gay were found guilty of manslaughter and spent 15 months in prison before their convictions were quashed.[citation needed]

In interviews for BBC Radio 4's File on 4 programme,[43] Professor Jean Golding and Professor Ashley Grossman both questioned the reliability of the Meadow paper. The naturally occurring condition diabetes insipidus was suggested as a more likely cause of an elevated salt level than deliberate salt poisoning.

See also

References

  1. ^ Mosley, Charles, ed. (2003). Burke's Peerage, Baronetage & Knighthood (107 ed.). Burke's Peerage & Gentry. p. 2656. ISBN 0-9711966-2-1.
  2. ^ "Reporter 428, 30 November 1998". reporter.leeds.ac.uk. Archived from the original on 16 April 2016. Retrieved 7 August 2018.
  3. ^ Meadow, Roy (May 1997). ABC of Child Abuse. BMJ books. pp. 100. ISBN 0-7279-1106-6.
  4. ^ Matthew Taylor (19 December 2003). "Cot death expert to face investigation". London: The Daily Mirror. Retrieved 18 March 2007.
  5. ^ "BBC:Sir Roy Meadow struck off by GMC". BBC News. 15 July 2005.
  6. ^ Shaikh, Thair. "Sally Clark, mother wrongly convicted of killing her sons, found dead at home", The Guardian, 17 March 2007.
  7. ^ "Alcohol killed mother Sally Clark". 7 November 2007. Retrieved 7 August 2018 – via news.bbc.co.uk.
  8. ^ "Media Summary of Judgment". judiciary.gov.uk. 26 October 2006. Archived from the original on 27 September 2007. Retrieved 17 March 2007.
  9. ^ a b c David Cohen (23 January 2004). "He Doesn't Like Women, Says Ex-Wife". Evening Standard. Retrieved 30 November 2023.
  10. ^ "Profile: Sir Roy Meadow". 10 December 2003. Retrieved 7 August 2018 – via news.bbc.co.uk.
  11. ^ "University of Leeds, List of Emeritus Professors". Archived from the original on 26 September 2012.
  12. ^ Meadow, Roy "Munchausen Syndrome by Proxy: The Hinterlands of Child Abuse", The Lancet, 13 August, pp. 343-5, 1977
  13. ^ "Beverly Allitt: Suffer the Children". The Crime Library. 10 May 2000. Archived from the original on 8 February 2007. Retrieved 6 February 2007.
  14. ^ Gene find casts doubt on double 'cot death' murders. The Observer; 15 July 2001.
  15. ^ Cassandra Jardine. Has Sally Clark's case changed attitudes to infant death?, The Telegraph, 16 March 2008.
  16. ^ "Sally Clark Appeal Court Judgment 2003 (Successful) | MOJO Scotland". Archived from the original on 17 February 2015. Retrieved 10 October 2015.
  17. ^ The Guardian 13 October 1999, page 5, author Paul Kelso
  18. ^ The Observer 10 November 1999, page 2, author Paul Kelso
  19. ^ a b c "Royal Statistical Society concerned by issues raised in Sally Clark case" (PDF) (Press release). Royal Statistical Society. 23 October 2001. Archived from the original (PDF) on 7 April 2008. Retrieved 25 April 2009.
  20. ^ "Archived copy" (PDF). Archived from the original (PDF) on 10 October 2016. Retrieved 13 October 2015.{{cite web}}: CS1 maint: archived copy as title (link)[full citation needed]
  21. ^ a b Watkins, S. J (2000). "Conviction by mathematical error?". BMJ. 320 (7226): 2–3. doi:10.1136/bmj.320.7226.2. PMC 1117305. PMID 10617504.
  22. ^ Joyce, Helen (September 2002). "Beyond reasonable doubt". Plus Magazine. Retrieved 15 September 2009.
  23. ^ Sally Clark website Archived 3 December 2015 at the Wayback Machine. Accessed 25 January 2023.
  24. ^ "Judge and Jury". Retrieved 25 January 2023.
  25. ^ Meadow, R (2002). "Personal paper: A case of murder and the BMJ". BMJ. 324 (7328): 41–43. doi:10.1136/bmj.324.7328.41. PMC 1121945. PMID 11777809.
  26. ^ Dyer, Clare (2005). "Pathologist in Sally Clark case suspended from court work". BMJ. 330 (7504): 1347. doi:10.1136/bmj.330.7504.1347. PMC 558274. PMID 15947383.
  27. ^ "John Sweeney on infant death". TheGuardian.com. 14 December 2003.
  28. ^ Shaikh, Thair (17 March 2007). "Sally Clark, mother wrongly convicted of killing her sons, found dead at home". The Guardian. ISSN 0261-3077. Retrieved 8 December 2023.
  29. ^ "Solicitor wrongly jailed for killing sons died from excess alcohol". TheGuardian.com. 8 November 2007.
  30. ^ "Alcohol killed mother Sally Clark". 7 November 2007.
  31. ^ R v Angela Cannings [2004] EWCA Crim 1 (19 January 2004)
  32. ^ Horton, Richard (2–8 July 2005). "In defence of Roy Meadow". The Lancet. 366 (9479): 3–5. doi:10.1016/S0140-6736(05)66798-0. PMID 15993209. S2CID 41571852.
  33. ^ "Cot death expert defends evidence". 1 July 2005. Retrieved 18 December 2020.
  34. ^ Clark, Stephen (2005). "Roy Meadow". The Lancet. 366 (9484). Elsevier BV: 449–450. doi:10.1016/s0140-6736(05)67048-1. ISSN 0140-6736. PMID 16084242. S2CID 32832108.
  35. ^ Stapely, Sue (1 July 2005). "Response by the Clark family to Richard Horton's comment in the July Edition of The Lancet". Sally Clark. Archived from the original on 7 May 2016. Retrieved 18 December 2020.
  36. ^ Dyer, Clare (2005). "Professor Roy Meadow struck off". BMJ. 331 (7510): 177. doi:10.1136/bmj.331.7510.177. PMC 1179752. PMID 16037430.
  37. ^ "Meadow apologises for 'misleading' cot death claim". The Guardian. 6 July 2005. Retrieved 18 December 2020.
  38. ^ "Frank Lockyer, Camilla Cavendish and Professor Sir Roy Meadow". Stowe Family Law. 12 January 2009. Archived from the original on 8 September 2018. Retrieved 18 December 2020.
  39. ^ Batt, John (2005). Stolen Innocence. Ebury Press. p. 121. ISBN 978-0-09-190569-9.
  40. ^ "Meadow ruling 'risk to witnesses'". BBC News. 16 July 2005. Retrieved 18 December 2020.
  41. ^ Blakemore-Brown, Lisa. "Sir Roy Meadow removes himself from the General Medical Council Register". Archived from the original on 5 February 2015.
  42. ^ Meadow, R (1993). "Non-accidental salt poisoning". Archives of Disease in Childhood. 68 (4): 448–52. doi:10.1136/adc.68.4.448. PMC 1029261. PMID 8503665.
  43. ^ BBC Radio 4, "Miscarriages Of Justice", transmission date 29 November 2005.

Bibliography

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