Although it is very rare, some mothers do commit the unthinkable act of killing their own children. According to Berman, "If there is indeed no suicidal behavior on her part, then typically it's homicidal behavior associated with a psychotic break or postpartum depression." Studies and experts agree on one common factor when mothers commit such an unthinkable crime: extreme mental illness. There are very few mothers in the world that do not have some type of mental illness that would kill their own children. According to the article, British law allows mothers to be charged with manslaughter rather than murder if they have a mental disorder. According to Phillip Resnick, an expert in maternal fillicide and co-author of a 2007 World Psychiatryy study, women who are convicted of infaticide in Britain often receive probation and mental health treatment referrals rather than incarceration. Following the Newton case, Caffese said "Unless there's a really unusual circumstance, a mother doesn't kill her children. I bet there were signs all along that were just missed." In conclusion, after researching why a mother would ever kill her own child, it was found that it would be unheard of to find a case where the mother did not have some type of mental illness.