Sir Samuel Roy Meadow (born 1933) is a retired British paediatrician, who first came to public prominence following a 1977 academic paper describing a phenomenon dubbed Munchausen Syndrome by Proxy (MSbP). For his work, ‘The Captive Mother’, he was awarded the prestigious Donald Paterson prize of the British Paediatric Association in 1968; in 1980 when a second professorial chair in paediatrics was inaugurated at St James’s University Hospital, Leeds, he was invited to accept it; in 1998, he was knighted for services to child health.  His work became controversial, particularly arising from the consequences of a belief he stated in a 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“. This became known to some as "Meadow's Law" and was influential in the thinking of UK social workers and child protection agencies, such as the NSPCC.
Meadow's reputation was severely damaged after he appeared as an expert witness for the prosecution in several trials, in at least one of which his testimony played a crucial part in a wrongful conviction for murder. 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 Sally Clark case. Clark was a lawyer wrongly convicted in 1999 of the murder of her two baby sons, largely on the basis of Meadow's evidence; her conviction was quashed in 2003 after she had spent three years in jail. Sally Clark never recovered from the experience, developed a number of serious psychiatric problems including serious alcohol dependency and died in 2007 from alcohol poisoning.
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.
- 1 Early career
- 2 Munchausen Syndrome by Proxy
- 3 Expert testimony
- 4 Cot death trial controversies
- 5 Statistical controversy
- 6 Sally Clark appeals
- 7 Trupti Patel
- 8 Angela Cannings
- 9 Aftermath
- 10 Ian and Angela Gay
- 11 Undue Influence on the Judiciary
- 12 See also
- 13 References
- 14 Bibliography
- 15 External links
Roy 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. 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." There is some controversy over these claims. According to the London Evening Standard “The Anna Freud Centre, however, has denied any record of him in their famous ‘war babies nursery’. It reported no record of him completing a formal training there. What's more, their chief executive, Professor Peter Fonagy, claimed the words he attributed to Anna Freud were a ‘total misrepresentation of her philosophy."
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. He retired with the title Emeritus Professor in 1998.
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.
Munchausen Syndrome by Proxy
In 1977, in The Lancet medical journal, Meadow published the theory which was to make him famous. 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.
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 in fact 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". Although this dictum is believed not to have originated from Meadow's own lips, it has become almost universally known as Meadow's law.
In 2003 Dr James Le Fanu wrote to The Lancet pointing out the self-agrandisment within the scientifically unfounded circular logic that Meadow used to promote the weight (and thereby influence upon juries) that his own opinions carried.
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, Roy Meadow claimed to have found 81 cot deaths which were in fact murder, but he had destroyed the data. 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 to 1 outsider in The Grand National for four successive years. The jury returned a 10/2 majority verdict of "guilty".
Meadow's 73,000,000:1 statistic was paraded in the popular press  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." The Society's president, Professor Peter Green, later wrote an open letter of complaint to the Lord Chancellor about these concerns.
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).
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. 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. (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.
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."
Sally Clark appeals
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 not involved in the case as "a breathtakingly intellectually dishonest judgement". Frank Ward, writing for MOJUK, preferred the term "intellectually incompetent".
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, 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". He went on to bemoan the time likely to be "wasted" on any further investigation of the case: "In today's world," he wrote, "it is inevitable that....formal letters of complaint from the family to the Police Complaints Authority, the General Medical Council, the royal colleges, or other statutory bodies will be treated with respect and will consume considerable resources."
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, 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'.
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.
Death of Sally Clark
Sally Clark died unintentionally on 16 March 2007 from acute alcohol intoxication. She never recovered from the serious psychological trauma resulting from the experience of the deaths of two children, then being unjustly convicted of their murder with subsequent imprisonment leading to her being separated from her third baby.
In June 2003, the CPS used Meadow's expert testimony against Trupti Patel, a pharmacist accused of killing three of her babies. After a highly publicised trial lasting several weeks, the jury took less than 90 minutes to return a unanimous verdict of "not guilty". Even then, a spokesperson for the prosecution stated that the crown would still be "very happy" to use Meadow's evidence in future trials. However, the Solicitor General for England and Wales, Harriet Harman (whose sister is Sarah Harman, a lawyer involved in another subsequent high-profile case where the parents had been accused of harming their children) effectively barred Meadow from court work; she warned prosecution lawyers that the defence should be informed of court criticisms of Meadow's evidence.
The following December Angela Cannings, a mother convicted on Meadow's evidence, was freed on appeal. She had been wrongly convicted of murdering two of her three babies, both of whom had died in their first few weeks of life. Following the quashing of her convictions, Meadow found himself under investigation by the British General Medical Council for alleged professional misconduct.
Cannings' case differed from Clark's in that there was no physical evidence. The prosecution rested upon what was perceived to be "suspicious behaviour" on the part of the mother (telephoning her husband instead of emergency services when one of the deaths occurred) and upon Meadow's opinion that she was an MSbP sufferer. He had told the jury that the boys could not have been genuine cot death victims because they were fit and healthy right up until the time of death (contradicting other experts who claim this is typical of SIDS cases). The prosecution had also rejected any genetic explanation, stating that there was no family history of cot death. Although no enumerated statistics had been presented, Meadow had told the jury that double cot death was extremely unlikely. The jurors took nine hours to return a guilty verdict.
Cannings had already lost one appeal but, in the wake of the Clark and Patel acquittals, the case was "fast tracked" for a second appeal. In the weeks that followed, an investigation by the BBC showed that the prosecution's "no family history" argument had been incorrect: at least two of Cannings' paternal ancestors had lost an abnormally large number of infants to unexplained causes, making a genetic predisposition to cot death highly plausible.
The appeal was heard in December 2003 and the Court of Appeal declared the original conviction unsafe and allowed Cannings' appeal.
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".
Some people expected that many convictions would quickly be overturned. In the event, however, 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.
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. This controversial interference in the GMC process 'incensed' Sally Clark.  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.
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".
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'. There is no evidence to refute the first excuse (legal advice). Also there is no contemporaneous evidence to support the latter (professional etiquette). Although Sally Clark was not a patient of Professor Meadow, as a professional witness in a very serious court case his professional duty towards her and her predicament implied that he owed her and her family the same standards of ethical behaviour as if she had been. Nowhere in the then current GMC 'Good Medical Practice' 1998 and 2001 guidelines is apologising for wrong doing or error precluded. In fact, on the contrary, in paragraph 17 (1998) and paragraph 20 (2001) an apology is encouraged. 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.  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 terrible for me, it must be awful for you.' As a Consultant Paediatrician and experienced court expert witness he must have known this was a disrespectful, inappropriate and inflammatory action. He was instructed by Clark's barrister Michael Mackey to 'go away'.
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.
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".
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" (see Richard Webster's article discussing the judgment.)
In 2004 Meadow’s ex-wife, Gillian Paterson, accused Meadow of seeing “mothers with Munchhausen 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.” The article also revealed that Meadow had starred in an amateur production of The Crucible by Arthur Miller, playing Judge Danforth who falsely and recklessly accuses women of witchcraft and child killing and sentences them to death. Meadow confided to a friend that “he found it an uncomfortable part because he identified with this judge more than he was happy with.”
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.
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", 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.
In interviews for BBC Radio 4's File on 4 programme, 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.
Undue Influence on the Judiciary
Frank Ward wrote for "Portia":-
"Sir Roy and a bevy of judges seem to be responsible for more than their fair share of miscarriages of justice. There was an incestuous arrangement between them - more serious still if it were an insidious one - where Sir Roy lectured the judges on child abuse matters and then gave evidence before them in individual cases. Hundreds of cases in fact. Now the use of one expert witness in so many cases is cause for alarm. This was an incredibly contrived process and you can well understand the bewilderment of the defendants at what was happening to them, knowing nothing of the hidden activity beyond the court room." 
The outcome of this growing relationship as a perceived eminent 'expert' was that each successful unjust prosecution of an innocent parent bolstered Meadow's reputation and made him a more dangerous participant in each and every trial that followed. Each success amounted to a growing conflict of interest for Meadow as each one of them strengthened, without any scientific proof, the impact of his now discredited 'Law". Each unwarranted 'success' made him a more formidable and dangerous prosecution witness in any future trial.
In 2001 broadcaster and journalist John Sweeney suggested an alternative to Meadow's Law:-
"One cot death is a tragedy, two cot deaths is a tragedy and three cots deaths is a tragedy"
In 2003 he wrote in regard once again to Meadow's Law and offered another alternative:-
"One miscarriage of justice is a tragedy, two is suspicious and three means there is something wrong - not with the accused - but the accuser."
- Meadow, Roy (May 1997). ABC of Child Abuse. BMJ books. p. 100. ISBN 0-7279-1106-6.
- Matthew Taylor (2003-12-19). "Cot death expert to face investigation". London: The Daily Mirror. Retrieved 2007-03-18.
- "BBC:Sir Roy Meadow struck off by GMC". BBC News. 15 July 2005.
- Shaikh, Thair. "Sally Clark, mother wrongly convicted of killing her sons, found dead at home", The Guardian, March 17, 2007.
- "Media Summary of Judgment". judiciary.gov.uk. 2006-10-26. Archived from the original on 2007-09-27. Retrieved 2007-03-17.
- "Professor created "Meadow's Law"". London: Daily Mail. 2004-01-21. Retrieved 2008-04-01.
- Cohen, David. "He doesn't like women, says ex-wife". The Evening Standard. Retrieved 10 October 2013.
- David Cohen (2004-01-23). "He Doesn't Like Women, Says Ex-Wife". The Evening Standard. Retrieved 2008-05-18.
- BBC profile: Sir Roy Meadow
- University of Leeds, List of Emeritus Professors
- Meadow, Roy "Munchausen Syndrome by Proxy: The Hinterlands of Child Abuse", The Lancet, August 13, pp. 343-5, 1977
- "Beverly Allitt: Suffer the Children". The Crime Library. 10 May 2000. Retrieved 2007-02-06.
- Gene find casts doubt on double 'cot death' murders. The Observer; July 15, 2001
- Cassandra Jardine. Has Sally Clark's case changed attitudes to infant death?, The Telegraph, 16 March 2008.
- The Guardian 13 October 1999, page 5, author Paul Kelso
- The Observer 10 November 1999, page 2, author Paul Kelso
- "Royal Statistical Society concerned by issues raised in Sally Clark case" (PDF) (Press release). Royal Statistical Society. 23 October 2001. Retrieved 25 April 2009.
- Watkins, Stephen J "Conviction by Mathematical Error?" , British Medical Journal, Vol. 320, pp. 2-3, 1 January 2000.
- Joyce, Helen (September 2002). "Beyond reasonable doubt". Plus Magazine. Retrieved 2009-09-15.
- Meadow, Roy "A Case of Murder and the BMJ", British Medical Journal, Vol. 324, pp. 41-43, 5 January 2002.]
- Claire Dyer, BMJ 2005;330:1347 "Pathologist in Sally Clark case suspended from court work"
- Batt, John (2005). Stolen Innocence. Ebury Press. p. 121. ISBN 9780091905699.
- Webster, Richard article discussing Appeal Court judgement
- Meadow, Roy "Non-accidental salt poisoning", Archives of Disease in Childhood, Vol. 68, pp. 448-452, 1993.
- BBC Radio 4, "Miscarriages Of Justice", transmission date 29 November 2005.
- Batt, John (2005). Stolen Innocence. Ebury Press. p. 392. ISBN 9780091905699.
- Schneps, Leila; Colmez, Coralie (2013). "Math error number 1: multiplying non-independent probabilities. The case of Sally Clark: motherhood under attack". Math on trial. How numbers get used and abused in the courtroom. Basic Books. ISBN 978-0-465-03292-1.
- Judgment of the Court of Appeal in the case of Regina vs. Cannings, Jan 2004.
- Meadow faces GMC misconduct hearing from The Guardian.
- 'Disappointed and disheartened' BBC News report on the reactions of the women who were jailed.
- GMC Fitness to Practice Panel finding of serious professional misconduct against Meadow, July 2005.
- Judgement in High Court appeal in case brought by Meadow against GMC finding of serious professional misconduct, Feb 2006.
- Court of Appeal judgement restoring the ability of the GMC to discipline misconduct by expert witnesses, Oct 2006.
- AsherMeadow, a web-based information resource devoted to Munchausen Syndrome by Proxy.
- Information on Munchausen Syndrome by Proxy, a website devoted to Munchausen syndrome and Munchausen Syndrome by Proxy by expert Dr. Marc Feldman.