‘A Crime of Almost Unspeakable Cruelty and Wickedness’: Gender,Agency and Murder in Scotland – The Case of Jeannie Donald

Introduction

Since the emergence of second-wave feminism in the 1970s, feminist scholars have generated a substantial body of literature within which the crimes of violent women have been analysed. Such theorists have paid particular attention to the impact that discourses of femininity have had on the labelling of female murderers as ‘mad’, ‘bad’ or ‘tragic victim’ – more ‘sinned against than sinning’ – to be pitied rather than punished (Allen, 1987; Ballinger, 2008: 49; Morrissey, 2003; Wilczynski, 1991; Worrall, 1990). Typically, these scholars have argued that the more female criminals adhere to traditional discourses of femininity, the more likely they are to be perceived through the ‘mad’ and/or ‘victim’ label, and thus treated more sympathetically than those who find themselves constructed through the ‘bad’ category. Therefore, while acknowledging that those women who challenge conventional femininity are more likely to be perceived as a threat to the heteropatriarchal social order and are socially constructed through the ‘bad’ category, it is nevertheless the case that feminist work has overwhelmingly focused on the types of violence that most easily fit into the ‘victim’ category, an obvious example here being female victims of domestic violence who retaliate by killing their male abusers. This type of analysis is laudable and has proved extremely important, not least in terms of its impact in achieving legal changes for those who stand accused of such crimes (Edwards, 2010; Fitz-Gibbon and Pickering, 2012; Norrie, 2010).

However, feminist theorists have also noted the negative aspect of this reliance on mad/victim subject positions. While it has undeniably ‘benefited individual women on their journey through the legal system, it has been to the detriment of women as a category, since an overemphasis on women as helpless, passive victims whose actions are unintentional’ serves to reinforce gender stereotypes in which women are regarded as irrational and overemotional (Ballinger, 2008: 49–50). As such, this subject position has arguably prevented substantive equality being achieved. Moreover, its existence unwittingly, but unavoidably, has been essential to the counter-construction and continuous existence of the ‘bad’ woman who has transgressed acceptable discourses of femininity and therefore deserves harsh punishment as a result of her ‘double deviance’ – having offended against womanhood itself as well as committing a crime. Within this context, the deconstruction of all such stereotypical gendered subject positions is a necessary first step in the fight for substantive equality between the sexes, involving a recognition of women as equal human beings, capable of experiencing the entire range of emotions, whether caring, angry or otherwise, in order to obtain full citizenship on a par with men (Morrissey, 2003: 25).

While a substantial body of feminist literature concerned with the mad/bad/victim subject positions has been produced in recent decades, feminist scholars have nevertheless been accused of avoiding ‘difficult’ cases – that is, cases in which female perpetrators appear to have transgressed and subverted discourses of femininity through the specific nature of their criminal behaviour. Morrissey, for example, has observed that ‘the selection of violent women acceptable to and therefore discussed within feminist legal theory…depends upon the offender’s personal politics and the type of violence committed’ (2003: 135).

More specifically, Birch has noted ‘the deafening silence from feminists on the subject of Myra Hindley’, which she finds unsurprising since ‘there is no easy way to appropriate her actions for the purpose of advancing the cause of women’ (1993: 34). ¹

In other words, women who have transgressed discourses around acceptable femininity, particularly those surrounding the ‘maternal instinct’, motherhood, and, more broadly, women’s supposedly ‘innate’ and ‘natural’ instincts to care for, and protect, the weak in society – especially babies and children – are likely to experience difficulty in mounting a sympathetic defence. This is true where both the criminal justice system and feminist theorists are concerned. If their transgression takes the form of actually harming, hurting or killing the weak and defenceless, the chances of a sympathetic hearing are yet further reduced, unless the crime can be classified as infanticide. This crime allows the perpetrator to be constructed as ‘mad’ rather than ‘bad’, and thereby allocated reduced, if any, agency (Wilczynski, 1991). In short, the greater the intentionality of a criminal act and/or the greater the transgression against femininity, the greater the condemnation is likely to be. Women who engage in acts of sexual violence and/or acts that can be perceived as actual torture, particularly against a child, can therefore be regarded as ‘“limit” cases of feminist theory…[since they] shatter irrevocably the stereotypes of femininity, exposing the bounds within which constructions of the feminine are erected’ (Morrissey, 2003: 135).

This article aims to challenge the accusation that feminist scholars avoid ‘difficult’ cases involving violent women who cannot easily be constructed as victims. In doing so, it contributes to the study of such ‘limit’ cases through analysing the case of Jeannie Donald, who not only committed the crime of killing a child who was not her own, but also sexually mutilated the victim’s body, both crimes rarely committed by women. I shall argue that relying on subject positions that construct violent women as lacking in agency prevents the development of a critical and adequate understanding and analysis of their actions, and ultimately plays an important role in denying women substantive equality. If substantive equality is to be achieved, it is important to allocate women the full range of human emotions – including those that threaten the ‘safe’ subject positions of women as passive and helpless victims who lack intention when committing violence (Morrissey, 2003: 25). Instead, it requires acknowledgement that cases such as that of Jeannie Donald demonstrate women’s capacity to apply a full spectrum of rationality when engaging in serious criminal activity. Within this context, no case should be ‘off limits’ for feminist analysis, despite the challenges that such extremely rare, yet also exceptionally violent crimes pose to traditional patriarchal values and the wider social order.

This is not to argue that violent women are the same as violent men. The gendered context within which both men and women act and react also forms an important part of feminist analysis. Fitzroy, for example, has argued that women’s choices often take place ‘within a generally oppressive and often extremely personally abusive context’. Nonetheless, women are active agents ‘who can and do make clear choices to perpetrate violence against others’ (2001: 9). Rather, it is a recognition that adequate explanation of female violence can only be achieved when it is removed from ‘the realm of the bizarre and extraordinary’ and instead recognized as potentially rooted in rational decision-making and agency (Morrissey, 2003: 22). This will involve the creation of subject positions that fall outside stereotypical constructions of the violent female as having reacted unintentionally, or as a result of oppression, yet which avoids sensationalizing such violent conduct (Ballinger, 2008: 50). In other words, violent crime perpetrated by women may be a ‘rational reaction to life stresses…as is often the case with men’ (Wilczynski in Morrissey, 2003: 33).

This article also contributes to what has been described as a major gap ‘in Scottish historical research on crime…the involvement of women in criminality’ (Kilday, 2007: 1). Not only has Scottish historical research focused overwhelmingly on men and labour history, it has also ‘tended to focus in and around the industrial belt’ (Brown and Ferguson, 2002: 2). Meanwhile:

[G]ender as a category of analysis, the conceptual leap that underpins historical understandings of culture, society, identity and experience in scholarship elsewhere in the world, has failed to penetrate the foundations of Scotland’s community of historians. (Abrams, 2006: 3)

Inevitably, when focusing on a relatively small and specific section of a population – in this case violent women within a localized community of Scotland – issues of specific cultural practices and ‘differences’, compared to the rest of the United Kingdom generally, and to England in particular, require acknowledgement. The article therefore seeks to avoid any confusion between ‘Britishness’ and ‘Scottishness’ so as not to obscure the specific political and cultural nature of the Scottish experience (Breitenbach et al., 1998: 44).

At a different level, Brown and Ferguson have argued that ‘women in Scotland suffer a double disadvantage of marginalisation within a male-dominated Scotland, as well as marginalisation within an English-dominated Britain’ (2002: 1). Moreover, while Scottish people have been regarded as ‘a more brutal and hardened people’ (Kilday, 2007: 5), Scottish women have been portrayed as ‘essentially passive and restrained’ (Brown and Ferguson, 2002: 3), within a broader ‘misogynistic and sexually repressed’ culture (Breitenbach et al., 1998: 45). While such a portrayal may be accurate in certain geographical locations during specific eras, it is equally accurate to state that such characteristics are not unique to the Scottish population, but are also applicable at certain times in certain places within the rest of the United Kingdom and beyond. Hence, it is also the case that authors writing exclusively on the topic of Scottish history have emphasized what individual nations within the United Kingdom have in common as well as how they differ (Breitenbach et al., 1998: 47). Leneman, for example, has observed that while marriage and divorce laws in Scotland were far more liberal than in England, causing greater equality between the sexes in this area, ‘legal equality…did not obliterate the sexual double standard. Scottish society was no less, and no more, patriarchal than any [other] society in western Europe at the time; laws were passed and enforced by men’ (2000: 212).

Thus, it is clear that certain features such as the discourses that make up acceptable and respectable femininity and masculinity (Collier, 1995a, 1995b; Naffine, 1990), the role of heteropatriarchy in maintaining the social order (Ballinger, 2012) and women’s under-representation in violent crime statistics compared to men’s (Brookman, 2005; Lacey, 2008: 9; Newburn and Stanko, 1994) were, and are, all present, albeit in varying degrees, within all UK nations. Hence, while it is important to recognize national specificity, for example, in relation to the Scottish criminal justice system, when exploring issues of agency and criminal women, as is the case in this article, it is defensible to rely on the scholarship generated from a variety of nations inside and outside the United Kingdom, without necessarily falling into the trap of exercising ‘British’ or ‘English’ imperialist domination. In their discussion of separate educational and legal systems in Scotland, Breitenbach et al. state, ‘we would not expect a detailed account of the Scottish situation, but we would expect to be written into the account rather than written out of it’ (1998: 54).

Given the sheer volume of literature and academic analysis that has become available since the advent of second-wave feminism with regard to English or ‘British’ criminal women, this article is produced in the spirit of writing one Scottish female offender ‘into’ these accounts.

Women and the Death Penalty in Scotland: Factual and Methodological Issues

A total of five women were sentenced to death in Scotland during the 20th century. All five cases involved women who had killed children and, unusually, all involved older children or teenagers. Hence, none could be classified as infanticide – a crime that is much more common among women (Jackson, 2002; Kilday, 2013). Even more unusual, in four of the five cases, the accused was charged with the murder of a child who was not her own, a crime usually associated with men. In three of the five cases, women were sentenced to death after having been found guilty of murder with their male partners, who also received the death sentence (JC26/1911/70; JC26/1922/2; JC26/1948/15). In the remaining two cases involving Jeannie Donald and Susan Newell, the women’s husbands had initially also been accused with them, but were both able to produce alibis which left the women alone in the dock (JC26/1934/72; JC26/1923/12).

All publicly available documents in the National Archives of Scotland relating to the five cases were examined; however, due to space restrictions, one case has been selected for in-depth analysis. Although there were certain shared features among some of the cases, each case was also unique, and there is no suggestion that the case of Jeannie Donald is representative of the four remaining cases. On the contrary, the case-study approach has been selected due to its suitability for ‘dismantling…pernicious gender stereotypes’ (Downing, 2013: 28) – in this case the social construction of appropriate femininity. ²

Only one part of the Donald trial transcript was available (Day 6 pp.658-756 in HH16/3/1/1). However, the entire transcript is reproduced in book form as part of the Notable British Trials series, published by William Hodge and Company. Advocate John Wilson, who edited the Trial of Jeannie Donald, took the precaution of asking both defence and prosecution counsel to read the manuscript prior to publication (Wilson, 1953: Preface ³ ). Moreover, it was standard practice to repeat ad verbatim trial proceedings in newspapers during the first half of the 20th century in both Scotland and England. Both sources have been incorporated into this article as substitutions for the missing parts of the transcript.

The Case

Jeannie Donald stood trial for the murder of her neighbour’s daughter, Helen Priestly, in July 1934. She was charged with having assaulted 8-year-old Helen in April 1934, by ‘insert[ing] her finger or an instrument into her private parts and inflict[ing] serious injury upon her, compress[ing] her throat with her hands, or, by some other method, did asphyxiate her, and did murder her’ (Indictment JC26/1934/72; Scottish Daily Express, 17 July 1934).

The alleged motive was rooted in an ongoing neighbour feud between Helen’s mother, Agnes Priestly, and Jeannie Donald, dating back 4 years, which had arisen as a result of ‘tittle-tattle’. Agnes had called Jeannie ‘creeping Jesus’ and considered her to be ‘a strange woman’. As evidence of this, she alleged that ‘acid had been thrown on a door which her husband had just painted; dust was spread purposely on the passage so as to imply that Mrs Priestly was not keeping the stair clean’ and Helen’s pram had been broken (JC26/1934/72). Agnes admitted she had no proof that Jeannie had been responsible for these acts. However, she testified that Jeannie would open the door and look ‘up the stairs after [Helen:]…The last occasion was two or three months ago’ (Scottish Daily Express, 17 July 1934). Conversely, Jeannie described Agnes ‘as a woman of violent temper, who had frequently maligned the prisoner, and alleged that Helen had called her coconut’ (JC26/1934/72).

Due to the ‘extreme violence [that] had been applied to the genitals’ (JC26/1934/72), it was initially thought that Helen had been raped, and Jeannie’s husband Alexander Donald was also charged with the crime. He was released after being able to establish that he had been at work at the time of the murder. Jeannie was now suspected of having inflicted the ‘extreme violence’ to Helen’s genitals in order to mislead the investigation by making it appear as if a man had caused the injuries and thereby leading suspicion away from herself (Transcript, 1953: 258; HH16/3/1/1/1).

Initially, Jeannie was suspected of having strangled Helen, immediately after which she had mutilated her genitals, an added dimension to child murder, suggesting considerable agency, rationality and presence of mind. Medical evidence, however, soon established a different, arguably even more damaging, sequence of events: After having been the victim of a minor assault, Helen had fainted due to a pre-existing thyroid condition. While unconscious, the genital mutilation was inflicted on her body. The shock of this secondary assault caused ‘a recovery of consciousness’ and vomiting, and the cause of death was asphyxiation due to inhalation of ‘vomited matter’ (JC26/1934/72 Medical Report; Wilson, 1953: 49). Thus, the circumstances surrounding Helen’s death were complex and, due to Jeannie’s refusal to discuss the case, involved a measure of speculation. Ultimately, a version of events became established which was broadly accepted by criminal justice personnel, the media and other commentators, again, out of necessity, involving speculation. Helen had formed the habit of knocking on Jeannie’s door whenever she passed, and running away, no doubt as a result of the ongoing hostility between the two families. Jeannie was thought to have been waiting for Helen’s knock in order to reprimand her. However, due to her medical condition, Helen fainted after a relatively minor assault. Jeannie, believing her to have died, immediately took action to cast suspicion away from herself. She inflicted the genital mutilation and hid the body in her home, after which she made an appearance at the entrance to the tenement, in order to establish her alibi by engaging a neighbour, Mrs Topp, in conversation (Wilson, 1953: 46). The entire sequence of events was believed to have taken no more than half an hour.

As this official truth gained acceptance, questions were raised as to whether this was a case of murder or culpable homicide, the Scottish version of manslaughter (Wilson, 1953: 48). However, this new sequence of events did not reduce the agency and rationality of Jeannie Donald. On the contrary, her presence of mind was emphasized by her ability to converse with Mrs Topp within minutes of Helen’s death, who testified they had had ‘an ordinary conversation’ (Transcript, 1953: 122). She also claimed to have seen different neighbours following a shopping trip, when she had in fact observed them from her window immediately after perpetrating the crime (Transcript, 1953: 127; Wilson, 1953: 49). Moreover, she carried on as normal the rest of the day – taking her own daughter to a dancing competition between 5 p.m. and 11 p.m., a period during which Helen’s body was hidden in her home, until she had an opportunity to transfer it into the hallway of the tenement block where the two families lived. There it was found early the following morning inside a sack.

While there was a wealth of strong circumstantial and incriminating evidence of Jeannie’s guilt, she maintained a complete silence about the crime, refusing to discuss it, even with her own defence counsel, who was consequently left in a position where the only available defence strategy was to attempt to discredit the case for the prosecution (Transcript, 1953: 44). The editor of the trial transcript, Wilson, described her as follows:

She was not given to useless displays of feeling. This strange, silent woman is said to have shown, during the six days of her trial, only two signs of emotion: once when her own loved daughter appeared in the witness-box as a Crown witness and, at the end, when the dreaded verdict of ‘guilty’ was pronounced and the inevitable sentence followed. (1953: 18)

A final key feature indicating Jeannie’s agency was the fact that she had acted alone. The most notorious case of a woman convicted in connection with child murder in England is undoubtedly that of Myra Hindley, who, during her 36 years of imprisonment, maintained the status of a national hate figure. Even after her death in 2002 – when ‘references to her as an icon of modern evil were ubiquitous’ (Murphy and Whitty, 2006: 4) – she remained despised as a manipulative, self-serving ‘schemer, prepared to trick anyone to be free’ (Stanford in Murphy and Whitty, 2006: 6). However, she acted with another person, Ian Brady, who was considered to be the main perpetrator by the sentencing judge. Thus, even by the standards of Myra Hindley whose image in popular discourse has remained that of a figure of unremitting and undiluted evil, the Donald case is an unusual and challenging one for feminist analysis. For while she committed a crime against one child only, and therefore was less prolific than Myra, the fact that she acted alone ensured there was no possibility whatsoever of reducing her level of agency and culpability. In comparison, commentators and scholars interested in creating a more complex subject position for Myra Hindley have considered her level of agency in relation to her infatuation with, and fear of, Brady. In this regard, he was a convicted criminal by the time he met Myra and 5 years her senior, whereas Myra’s life, until that point, had been ‘unremarkable’ (Birch, 1993; Ballinger, 1996; French, 1996: 33; Morrissey, 2003; Murphy and Whitty, 2006). As such, her agency has been analysed, not only in relation to her role as a child killer, but also in relation to subject positions such as ‘naive dupe’ and victim (Morrissey, 2003: 135). ⁴ In contrast, by acting alone, Jeannie had eliminated the possibility of occupying a submissive subject position. Instead, her agency was beyond dispute and the possibility of claiming spectator status, victim status or innocent dupe status through oppression, fear or naivety, did not, and could not, exist.

Her agency and lack of victimhood were further reinforced by social class. Although belonging to the working class, Jeannie could not claim abject poverty as a mitigating factor, unlike other Scottish women offenders such as Susan Newell who was executed in 1923 for killing 13-year-old John Johnston for the sake of the ‘few coppers’ he had earned selling newspapers (Glasgow Herald, 20 September 1923; JC36/43), or Catherine Smith, sentenced to death in 1911, whose skirt had been pawned to raise money for food (HH16/119/21; JC36/24), or Helen Harkness who received the death sentence in 1922 for killing 14-year-old Elizabeth Benjamin in connection with robbing her of the takings she had collected on behalf of her father’s business (JC36/38). By contrast, Jeannie was a ‘respectable’ housewife, whose husband worked as a hairdresser and was able to support his family to a standard which went well beyond providing the bare necessities. Consequently, she was considered to have ‘lived under comfortable circumstances’ (JC26/1934/72 Medical Report). ⁵ Hence, the possibility of constructing Jeannie as a victim of her social-economic background did not exist.

Nor could Jeannie be situated within the ‘mad’ subject position for there was never any doubt about her sanity. On the contrary, Professor Henderson, a consultant in psychiatry who examined Jeannie in prison, observed that:

Her conversation was relevant and coherent…there was no impairment of her intellectual processes. There was no evidence of hallucinations or other signs of a disordered mentality. The general impression received was that of a healthy, capable woman who had held responsible positions and…there was no evidence of any organic disease. (JC26/1934/72 Medical Report; HH16/3/1/1/1)

In sum, unlike three of the four other cases of women who were sentenced to death in Scotland during the 20th century, Jeannie’s crime could not be reduced to poverty-related issues. Nor could it be constructed through the ‘mad’ discourse, as a crime caused by mental illness or insanity. Thus, in the absence of any mitigating circumstances whatsoever, the motive behind the crime increasingly appeared to be vindictiveness and, arguably, maliciousness. Even if the actual death had been unintentional, the mutilation of Helen’s genitals undeniably had been carried out with great deliberation (JC26/1934/72) and indicated her ability and willingness to use violence instrumentally (Fitzroy, 2001: 18). Nonetheless, because the sequence of events outlined above had been accepted as accurate, Scottish law allowed Jeannie to plead guilty to culpable homicide, the punishment for which excluded the death sentence (Wilson, 1953: 15). However, once again, Jeannie’s agency was noted for its presence. While her self-imposed silence excluded her rationale for her behaviour, there was broad agreement between legal personnel, the media and lay observers that she was engaged in a ‘strategic use of silence’ (Carrillo-Rowe and Malhotra, 2013: 7, original emphasis) as a deliberate, if risky, strategy to achieve a not guilty verdict and thus avoid punishment altogether. In short, by denying all knowledge of the crime, Jeannie was counting on the circumstantial evidence falling short of proving her guilt beyond reasonable doubt, which could have led to the Scottish verdict of ‘not proven’. Hence, she could not admit to culpable homicide, even though it would have ensured the avoidance of the death penalty, for it would also have meant any ‘hope of acquittal would have disappeared completely’ (Wilson, 1953: 50; HH16/3/1/1/1). Lest there was any doubt about this point in the jury’s mind, the Lord Justice Clerk issued very specific instructions:

[I]t may be possible for the jury to say that the crime that has been committed is less than murder. Here, there is no such alternative open to you. I must give you the clearest and the most explicit direction…if the Crown have [sic] succeeded in bringing home guilt to the accused, then the crime is murder. The only verdicts that are open to you in this case are Not Guilty, Not Proven, or Guilty of Murder. (Transcript, 1953: 263–264)

Conclusion

This article has aimed to demonstrate that feminist theorists do not necessarily shy away from ‘limit’ cases – difficult cases where it is virtually impossible for the female perpetrator to occupy the ‘victim’ or ‘mad/bad’ subject position. On the contrary, feminism understands – indeed embraces the fact – that a debunking of sexist and stereotypical subject positions – mad, bad or victim – will result in an increased critical and nuanced understanding of responsibility and agency. There has been no attempt in this analysis to ‘recuperate’ Jeannie back into the fold of acceptable femininity or to celebrate her crime as a form of resistance to heteropatriarchy. Instead, while her behaviour undoubtedly stands as ‘subversive of heteropatriarchal ideologies’, her cruelty and brutality have not been condoned; nor should it be, for it is ‘vital that we acknowledge violence as human, rather than as solely masculine’ (Morrissey, 2003: 162, 163), in the struggle for substantive equality. Such an analysis is to be welcomed, not feared:

because an emphasis on women as irrational, pathological and over-emotional creatures, whose crimes are unintentional, ‘undermine a concept of women in general as fully fledged moral subjects and responsible agents’, in possession of full citizenship on par with men. (Ballinger, 2016: 4, citing Morrissey)

Crucially, the case has evidenced that women’s violence – despite presenting a challenge to dominant discourses of femininity – does not automatically or necessarily result in harsher punishment. The operation of the criminal justice system is complex and the social division of gender forms one important strand of that complexity. Yet, as this case has demonstrated, it can be uncoupled when a defendant refuses to ‘play the gender card’, allowing other strands to emerge in its place. The benefit of doubt can be regarded as one such strand and complexity – a variable that has an unpredictable impact on the final outcome of the defendant’s punishment. Thus, when discussion took place about releasing Jeannie after less than 10 years’ imprisonment, legal personnel were aware of Professor Smith’s suspicion that Jeannie had deliberately strangled Helen ‘in a desire to cover up’: ‘Nevertheless…it seems clear that there was no premeditation or intention to murder at the time of the first blow’ (HH16/180, emphasis added).

This article has also demonstrated that while the stereotypical constructions imposed on violent women as mad or bad have served as a powerful strategy for silencing rational explanations that women may offer for their behaviour (Ballinger, 2005), the tool of silence can also be employed by the perpetrator herself as a deliberate strategy to avoid taking responsibility for her crime. Silence therefore can also be utilized against the criminal justice system as well as by it, as a muted form of resistance, and as a site of contestation and challenge to the state’s adversarial strategy within the courtroom. In that sense, this case confirms Smart’s point that ‘the subject, Woman, is not merely subjugated; she has practiced the agency of constructing her subjectivity as well’ (1992: 7).

To elaborate, Jeannie’s case has exposed the lack of official tools available to law once a defendant has embarked upon a conscious and rational strategy of silence. The legal system, deprived of its gendered subject positions, was forced onto a terrain of speculation, confusion and bafflement when confronted with a female occupying her subject position from which she simply refused to cooperate at any level of the legal process during the trial. Regardless of what was said or written about her, she instead presented herself as a subject entirely lacking in the usual discourses of mad, bad or victim. She simply remained sane, rational, reasonable and polite before and during her trial, as well as throughout her imprisonment, and apart from the confession, never commented on the crime of which she had been found guilty. ¹⁰ In documenting her case, this article has therefore also fulfilled its second aim, namely to make a contribution to historical research on the topic of Scottish women’s involvement in criminality.

Finally, the overall aim of the article – to challenge the claim that ‘Scottish women of any historical interest are curiously rare’ (McDairmid in Breitenbach et al., 1998: 44) – has also been fulfilled. For while the crime for which she was found guilty is indeed ‘rare’ among women, Jeannie Donald herself is unarguably of great ‘historical interest’ to scholars interested in contributing to the major gap ‘in Scottish historical research on crime…the involvement of women in criminality’ (Kilday, 2007: 1).