This page brings together scientific research and academic publications concerning adolescent brain development, mental health and criminal responsibility.
The materials explore how young people's development, psychological wellbeing and other factors may be relevant to understanding behaviour and sentencing.
These publications provide wider research context. They do not, by themselves, establish what caused Carly Gregg's actions or determine the legal questions in her case. Visitors are encouraged to read the original studies and consider their findings and limitations.
Mental Health and Neurodevelopmental Disorders, Criminality, and Criminal Responsibility
Explore the connection between mental health and neurodevelopmental disorders, criminality, and criminal responsibility.
The Developmental Perspective on Juvenile Justice — Why Children's Maturity Matters
In this academic paper, developmental psychologist Laurence Steinberg examines how decades of research into adolescent psychological and brain development have influenced the way young people are treated within the criminal justice system.
The paper discusses the developmental approach to juvenile justice, including its influence on Restatement of Children and the Law, which considers how legal principles should account for the differences between children and adults.
Carly Gregg was just 14 years old when the events occurred. This research provides important context for understanding why a child's developmental maturity should be considered when evaluating responsibility, sentencing and opportunities for rehabilitation.
A developmental approach does not mean ignoring the seriousness of an offence or removing accountability. It recognises that young people are still developing and that their capacity for judgement, self-regulation and change differs from that of fully mature adults.
The paper offers a broader perspective on juvenile justice policy. It does not determine the appropriate legal outcome in Carly's individual case.
Why Adolescent Brain Development Matters in Sentencing
Neuroscientific research into adolescent brain development shows that the brain systems involved in emotional responses, impulse control, risk assessment and long-term planning continue to develop throughout adolescence and into early adulthood.
During adolescence, heightened sensitivity to emotions and rewards can interact with still-developing abilities to regulate behaviour and consider long-term consequences. These developmental differences are important when considering a young person's culpability, circumstances and potential for rehabilitation.
Adolescents differ from adults in important aspects of brain development, including emotional regulation, impulse control, decision-making and sensitivity to external pressures.
Neuroscientific research indicates that these abilities continue developing into early adulthood. This does not remove responsibility for serious actions, but it is relevant when considering a young person's circumstances, culpability and potential for rehabilitation.
The United States Supreme Court has recognised the developmental differences between children and adults in decisions including Roper v. Simmons (2005), Graham v. Florida (2010) and Miller v. Alabama (2012).
These principles raise important questions about how Carly's age and individual circumstances were considered during her trial and sentencing.
In August 2026, the Mississippi Supreme Court described Carly's murder sentence as life imprisonment rather than life without parole. Her actual parole eligibility remains a separate question requiring clarification.
Justice for Carly Gregg believes that accountability, fairness and the possibility of rehabilitation all deserve careful consideration.
The Late James Garbarino Professor Emeritus
Education Ph.D., Cornell University
The following biographical statement describes Professor Garbarino's research interests and professional experience. It is reproduced as a historical account of his work.
My research focuses on issues in the social ecology of child and adolescent development. I have a long standing interest in a wide range of violence-related issues - war, child maltreatment, childhood aggression, and juvenile delinquency. In 1991 I undertook missions for UNICEF to assess the impact of the Gulf War upon children in Kuwait and Iraq, and have served as a consultant for programs serving Vietnamese, Bosnian and Croatian children. I also serve as a scientific expert witness in criminal and civil cases involving issues of trauma, violence, and children. In all these issues I am concerned with how developmental processes are shaped by the human ecology in which they occur, and have a particular interest in matters of spirituality and identity in this process. After completing a project on physical aggression in girls (resulting in a book entitled See Jane Hit: Why Girls Are Growing More Violent and What We Can Do About It), I am currently working on a project dealing with childhood in the face of the terrorist threat.
Selected Publications by Professor James Garbarino
Garbarino, J. and DeLara, E. (2002) And Words Can Hurt Forever: How to Protect Adolescents from Bullying, Harassment, and Emotional Violence (NY: Free Press, 2002
Garbarino, J. and Bedard, C. (2001) Parents Under Siege: Why You Are the Solution, Not the Problem, in Your Child's Life. NY: Free Press.
Garbarino, J. (1999) Lost Boys: Why Our Sons Turn Violent and How We Can Save Them. (NY: Free Press).
Garbarino, J. (1995) Raising Children in a Socially Toxic Environment (1995). San Francisco: Jossey-Bass Publishers.
Academic Research — Adolescent Development and Criminal Responsibility
This influential academic paper by Laurence Steinberg and Elizabeth S. Scott examines how developmental immaturity affects young people's judgement, decision-making and criminal responsibility.
Although the paper focuses on juvenile capital punishment, its discussion of adolescent development provides important background for wider questions about youth sentencing, accountability and rehabilitation.
The research is provided for educational context and does not establish the legal outcome of Carly Gregg's case.
Juvenile Justice Policy and Practice — A Developmental Perspective
This academic paper by Kathryn Monahan, Laurence Steinberg and Alex R. Piquero examines how research into adolescent development has influenced approaches to juvenile justice, particularly the balance between punishment and rehabilitation.
The authors discuss how young people's decision-making, brain development and capacity for change differ from those of adults. They also explore how developmental research has contributed to changes in juvenile sentencing policy and legal thinking.
Carly Gregg was only 14 years old when the events occurred. This research provides important context for considering how a child's age, psychological maturity and potential for rehabilitation should inform discussions about criminal responsibility and punishment.
The paper highlights why rehabilitation remains an important consideration in juvenile justice, even when an offence is extremely serious. Recognising developmental differences does not mean removing accountability or overlooking the devastating loss of Ashley Gregg's life.
This research offers a broader scientific and policy perspective. It does not determine the appropriate sentence or legal outcome in Carly's individual case.
Adolescent Development — Accountability, Rehabilitation and the Capacity for Change
In this 2012 interview published in Science, developmental psychologist Laurence Steinberg discusses how research into adolescent brain development helped inform landmark US Supreme Court decisions concerning the punishment of young offenders.
Steinberg explains that adolescents should be held accountable for serious offences, but their developmental immaturity must also be recognised. Young people are still changing psychologically and neurologically, and their behaviour during adolescence does not necessarily predict who they will become as adults.
This is particularly relevant to Carly Gregg, who was just 14 years old when the tragedy occurred. The seriousness of her actions must be acknowledged, but so must her developmental immaturity and potential for rehabilitation.
Steinberg also highlights the difficulty of predicting whether a young person who commits a violent offence will continue to behave violently in adulthood.
A terrible act committed at 14 should not automatically be treated as proof of an unchangeable character or a lifetime of dangerousness.
This interview provides important scientific context for considering juvenile sentencing, accountability and the possibility of personal growth. It does not determine Carly's individual risk, rehabilitation prospects or legal outcome.
Juveniles’ Competence to Stand Trial — Why Age and Understanding Matter
This important academic study by Thomas Grisso, Laurence Steinberg and colleagues examines whether adolescents possess the same abilities as adults to understand criminal proceedings, make informed legal decisions and assist their lawyers in preparing a defence.
The researchers assessed 927 adolescents and compared their abilities with those of 466 young adults. Their findings identified significant developmental differences, with younger adolescents particularly likely to experience difficulties in abilities relevant to competence to stand trial.
Carly Gregg was just 14 years old when the events occurred and 15 when she stood trial. This research raises important questions about how a young teenager understands complex legal proceedings, evaluates advice and participates in decisions that may affect the rest of their life.
Competence to stand trial is distinct from criminal responsibility. It concerns whether a defendant can understand the proceedings and assist in their defence, rather than whether they were responsible for the offence itself.
This study does not establish that Carly was legally incompetent to stand trial. Such a determination requires an individual legal and clinical assessment. The research demonstrates why developmental maturity deserves careful consideration when children face serious criminal proceedings.
Neuroscience and the US Supreme Court — Why Adolescent Maturity Matters
In this academic paper, developmental psychologist Laurence Steinberg examines how scientific research into adolescent brain development influenced landmark US Supreme Court decisions concerning the criminal responsibility and punishment of young people.
The research explains how adolescents differ from adults in psychological and neurological maturity, and why these differences are relevant when courts consider culpability and sentencing.
Carly Gregg was only 14 years old. This research provides important context for understanding why her developmental age matters when considering responsibility, punishment and the potential for rehabilitation.
Recognising adolescent immaturity does not remove accountability for serious offences. It means acknowledging that children are still developing and should not automatically be judged according to the same expectations as fully mature adults.
The paper provides a scientific and legal perspective on juvenile justice. It does not determine the legal outcome of Carly's individual case.
Adolescent Cannabis use and Risk of Psychotic Bipolar Disorders
This 2026 study, published in JAMA Health Forum, examines associations between adolescent cannabis use and the subsequent diagnosis of psychotic, bipolar, depressive and anxiety disorders.
The research provides important context for understanding adolescent mental health and potential risk factors. However, an association does not establish that cannabis use caused a particular psychiatric condition, nor does this study establish what happened in Carly Gregg's individual case.
The original research paper is provided below for visitors to examine its findings and limitations.
Carly's Journal — Understanding the Wider Context
During Carly Gregg's trial, evidence concerning vaping and her mother's search for vapes became part of the account of events leading up to the tragedy of 19 March 2024.
However, Carly's journal provides additional context that should not be overlooked.
In an entry dated 12 March 2024, just one week earlier, Carly described emotional distress, feelings of numbness, anger and regret, and an experience she herself referred to as a possible psychotic break. She also wrote positively about therapy and her efforts to manage her feelings.
These writings do not establish a medical diagnosis or explain precisely what happened on 19 March. Nor do they prove that cannabis use caused or prevented any particular symptoms.
They do, however, raise important questions about Carly's emotional wellbeing, the difficulties she was experiencing and whether those circumstances were fully understood.
Reducing the events of that day to a dispute about vapes risks overlooking this wider context. Understanding the tragedy requires careful consideration of the evidence, including Carly's age, mental health history, journal writings and the testimony presented at trial.
Young Adulthood as a Transitional Legal Category — Development, Maturity and Justice
In this academic paper, Elizabeth S. Scott, Richard J. Bonnie and Laurence Steinberg examine how scientific research into brain development, psychological maturity and social change has challenged traditional assumptions about adulthood within the criminal justice system.
The authors explore whether young adulthood should be recognised as a distinct developmental stage in law and justice policy, rather than assuming that everyone becomes fully mature upon reaching the age of 18.
Although this paper focuses primarily on young adults rather than younger adolescents, it provides important wider context for Carly Gregg's case. Carly was only 14 years old when the events occurred, an age at which developmental maturity is an especially important consideration.
The research highlights why age, maturity and capacity for change deserve careful attention when considering criminal justice responses. It also contributes to wider discussions about proportionate punishment and opportunities for rehabilitation.
Recognising developmental differences does not diminish the seriousness of Ashley Gregg's death or remove the need for accountability. It encourages a justice system that considers both the harm caused and the developmental stage of the person responsible.
This paper provides broader scientific and policy context. It does not establish the appropriate legal outcome in Carly's individual case.

Understanding Neurodevelopmental Disorders
Neurodevelopmental disorders (NDDs) encompass a range of conditions that affect the development of the nervous system. Individuals with NDDs may face challenges in communication, social interaction, and behavior. It is crucial to consider the impact of NDDs on an individual's actions and criminal responsibility.

Addressing Criminality and Mental Health
The intersection of criminality and mental health is complex. Many individuals with mental health issues may come into contact with the criminal justice system. It is essential to provide support services and advocate for fair treatment for individuals with mental health concerns.

Implications for Criminal Responsibility
Courts must take into account the influence of mental health and neurodevelopmental disorders when determining criminal responsibility. Failure to consider these factors can lead to unjust outcomes. It is crucial to raise awareness and educate the community about the impact of these conditions on criminal behavior.
➡️ A life sentence doesn’t solve the problem.
➡️ Ignoring mental illness only ensures the cycle continues.
➡️ Justice without mental health awareness is not Justice.
We need:
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Development-informed sentencing
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Access to comprehensive psychiatric assessments before trial
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Treatment options—not just prison → Mental health treatment and rehabilitation alongside accountability
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Trauma-informed courtrooms
Mental Illness, Criminal Responsibility and the Limits of Historical Legal Standards
The M'Naghten Rules originated in 1843 and continue to influence legal approaches to the insanity defence. However, the legal tests applied in the United States differ between jurisdictions, and not every state follows the same standard.
These rules focus on particular questions about a defendant's mental state at the time of an offence, including whether a mental disorder prevented them from understanding the nature of their actions or knowing that those actions were wrong.
But psychiatric conditions and neurodevelopmental differences can affect people in complex ways. Symptoms such as dissociation, hallucinations, memory disturbances and impaired judgement deserve careful clinical consideration, even when they do not meet the legal threshold for an insanity defence.
Carly Gregg was only 14 years old when the events occurred. Her psychiatric history and developmental maturity raise important questions about how mental health evidence should be understood in criminal proceedings. These questions do not, by themselves, establish legal insanity or remove criminal responsibility.
Carly received a life sentence following the death of her mother, Ashley Gregg. Recognising the devastating seriousness of that loss does not prevent us from asking whether the justice system gives sufficient consideration to adolescent development, mental health treatment and rehabilitation.
Mental illness and legal accountability can coexist. A fair justice system should take both seriously.
The M'Naghten rule was created in
1843
The M'Naghten Rules were established in 1843 following the case of Daniel M'Naghten. They set out a legal test for the insanity defence, focusing on whether a person, because of a disease of the mind, understood the nature and quality of their actions or knew that what they were doing was wrong.
The rules remain influential in England and Wales, and versions have been adopted in some US states. However, insanity laws vary between jurisdictions.
Mississippi continues to use the M'Naghten Rule as its legal standard for the insanity defence.
Other US states that use the M'Naghten Rule include:
Alabama, California, Florida, Iowa, Louisiana, Minnesota, Nebraska, Nevada, New Jersey, North Carolina, Ohio, Oklahoma, Pennsylvania, South Carolina, South Dakota and Washington.
Several additional states, including Alaska, Arizona, Colorado, Georgia, Missouri, New Mexico and Virginia, use modified M'Naghten-based standards or combine elements of the rule with other legal tests.
The precise requirements vary between states. A psychiatric diagnosis alone does not automatically establish legal insanity, and the M'Naghten Rule is concerned with a person's mental state at the time of the offence.
The continued use of this nineteenth-century legal framework raises important questions about how modern psychiatric knowledge and adolescent development are considered in criminal proceedings.
Daniel M'Naghten c. 1856
"Every man is to be presumed to be sane, and ... that to establish a defence on the ground of insanity, it must be clearly proved that, at the time of the committing of the act, the party accused was labouring under such a defect of reason, from disease of the mind, as not to know the nature and quality of the act he was doing; or if he did know it, that he did not know he was doing what was wrong.
US Insanity Defence Standards — Historical Overview
This map illustrates how different US states have used varying legal standards for the insanity defence, including versions of the M'Naghten Rules and the American Law Institute (ALI) test.
State laws and legal interpretations can change over time. This map should be viewed as a historical illustration rather than a definitive representation of current law in every state.
There are several studies showing that a successful insanity defense occurs in less than 1 percent of all criminal prosecutions,” said Jeffrey Metzner, M.D., immediate past president of the American Academy of Psychiatry and Law (AAPL) and chair of APA’s Council on Psychiatry and the Law.
We need:
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Proper mental health evaluations in juvenile courts
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Judges and juries trained to understand trauma and neurodevelopmental disorders
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Compassion without losing sight of accountability
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Laws that reflect modern science, not Victorian-era rules.
What happened to Carly is not just her tragedy.
We should all be asking: How many more young lives will we lock away instead of trying to heal?
Neurodevelopmental Disorders and Criminal Responsibility — Academic Research
This 2022 research article by Jeffrey Guina and colleagues, published in the Journal of the American Academy of Psychiatry and the Law, examines how neurodevelopmental disorders, including autism and intellectual disabilities, can affect assessments of criminal responsibility.
The authors explore how difficulties involving comprehension, reasoning, social cognition and behavioural regulation may be relevant to legal evaluations, and why the criteria for an insanity defence vary between jurisdictions.
This research highlights the importance of comprehensive, individualised psychiatric assessments. It provides useful context for considering how mental health and developmental factors are evaluated in criminal proceedings, without establishing any particular diagnosis or legal conclusion in Carly Gregg's case.
International Cases — Children, Mental Health and Criminal Responsibility
Courts around the world have faced difficult questions about how psychiatric medication, mental health conditions and adolescent development should be considered when children are accused of serious crimes.
The cases of Christopher Pittman in the United States and R v PS in England and Wales illustrate different legal approaches. In one case, an antidepressant-related defence was rejected; in the other, new evidence of a neurodevelopmental condition contributed to a reduced minimum custodial term.
Although neither case determines the legal outcome for Carly Gregg, both highlight the importance of carefully examining psychiatric evidence, developmental maturity and individual circumstances when a child's future is at stake.
Original Judgment and Contemporary News Sources
The following sources provide further information about the two cases discussed above.
The original Court of Appeal judgment in R v PS explains how new psychiatric evidence influenced sentencing. Contemporary reporting on Christopher Pittman's trial documents the antidepressant-related arguments presented by his defence and the jury's decision to reject them.
These cases involved different facts, legal systems and medical evidence. They are presented for comparison and do not establish what caused Carly Gregg's actions or determine the appropriate legal outcome in her case.
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In Mississippi, the insanity defense is rarely successful. While defendants are presumed sane, if a reasonable doubt of sanity is raised, the prosecution must prove sanity beyond a reasonable doubt. Juries determine sanity, but acquittals based on insanity are rare.
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Mississippi faces significant challenges related to mental health, including high rates of mental health conditions and a strong stigma surrounding mental illness. This stigma, lack of awareness, and limited access to care continue to be major barriers to mental health support in the state.
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A significant percentage of adults in Mississippi report symptoms of anxiety and/or depressive disorders, often exceeding national averages.
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Many Mississippians hesitate to seek help for mental health concerns due to the stigma surrounding mental illness and a lack of understanding about it.
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People struggle with mental health every day, but location can matter in terms of treatment options and other mental health services.
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A study from Soliant analyzed the best and worst states for mental health by evaluating data from the Centers for Disease Control and Prevention and the U.S. Bureau of Labor Statistics.
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The study scored each state by measuring factors that impact mental health including unemployment rate, participation in physical activity, disconnected youth rate, access to healthy foods and the frequency of "poor mental health days" reported by the population.
Mississippi's Mental Health Ranking — Soliant 2025 Report
According to Soliant's 2025 Best States for Mental Health Report, published in December 2024, Mississippi ranked 46th out of 50 states, with a score of 31.5 out of 100.
The ranking considers several indicators associated with mental health and wellbeing, including poor mental health days, unemployment, physical activity, disconnected youth and access to healthy food.
This is a broader wellbeing ranking, not a direct measurement of the quality of psychiatric treatment available in Mississippi.
Source: Soliant Health, 2025 Best States for Mental Health Report.