Marie Noe

Case overview

Marie Noe was convicted in June 1999 of murdering eight of her children. Between 1949 and 1968, eight of the ten Noe children died of mysterious causes which were then attributed to sudden infant death syndrome. Two other children died of natural causes.

Noe later pleaded guilty to eight counts of second-degree murder and was sentenced to twenty years of probation. She agreed to psychiatric study as part of the plea agreement.

Background

Marie Noe was born in 1928. She was 77 when she pleaded guilty in 1999.

Noe had scarlet fever at age five and later credited it as the cause of learning difficulties. She dropped out of school as a young teenager to work and help care for a niece, born to one of her older sisters when Marie was 12 and raised as Marie’s sister.

Marie and Arthur Noe met at a private club in the West Kensington neighborhood of Philadelphia. After a brief courtship, the couple eloped. The couple proceeded to have ten children.

Noe had a long and documented case of mental illness. Police and investigators later described concerns about her mental state, including that she appeared “slow in answering questions,” constantly called upon husband to help her, and appeared either hypothyroid or under par mentally. A physician also described her as an “unstable schizophrenic personality” who “quite possibly is psychotic.” A psychiatrist described her as loving attention and making constant reference to treatment. Investigators could not locate records of treatment, though she recalled attending psychoanalytic sessions at Temple.

The offence

Between 1949 and 1968, ten children born to Marie Noe and Arthur Noe died between the ages of 5 days and 14 months. Noe later admitted to smothering four of her children after police questioning and later pleaded guilty to eight counts of second-degree murder.

Noe claimed that the children died in their sleep. In each case described in the proceedings, she was at home alone with the children at the time of the deaths. Under the plea agreement, prosecutors accepted her guilty plea to eight counts of second-degree murder.

Investigation

Interest in the case was renewed after publication of the 1997 book The Death of Innocents, about New York woman Waneta Hoyt, and an investigative article that appeared in the April 1998 issue of Philadelphia magazine. The author of the Philadelphia article turned over investigation results to the Philadelphia Police Department in March 1998.

Upon questioning by police after receiving the material, Mrs. Noe admitted to suffocating four of her children. She stated that she could not remember what happened to the other four children who died under similar circumstances.

In August 1998, she was charged with first-degree murder.

During investigation work that followed, investigators and officials also considered the financial circumstances of the Noes. Police described that the parents had taken out insurance policies on six children.

Researchers and investigators discussed the influence of scientific developments on unsolved infant-death cases, including that after sudden infant death syndrome, or SIDS, was defined in 1969, doctors believed the reason the infants died, while prosecutors said the police kept the investigation alive for decades because of unique circumstances of the deaths.

Arrest and pretrial status

Noe was questioned by police in March, when she admitted suffocating four children.

Since her arrest, Noe had been released from jail on $500,000 bond and ordered confined to her home with an electronic-monitoring bracelet.

At a bail hearing in August, prosecutors described Mrs. Noe as a killer who shouldn’t be allowed on the streets. Assistant District Attorney Jay Feinschi called her “as much a mass murderer as Ted Bundy.”

Deputy District Attorney Charles F. Gallagher said: “It's important for the medical community and the legal community that she admit theses murders and ...something good will come out of the analysis.”

Defense attorney David Rudenstein said: “This is not one of those situations where we have a heart of a killer,” and later said: “This is not one of those situations where we have a heart of a killer” (as used in court discussion), and also said Noe’s confession was taken under “abominable circumstances” and she was led to believe she had no choice but to sign it.

Trial and plea

A plea agreement was reached in which Mrs. Noe admitted to eight counts of second-degree murder.

On June 28, 1999, Marie Noe pleaded guilty to eight counts of second-degree murder.

As a condition of the plea agreement, Noe agreed to psychiatric study in hopes of identifying what caused her to kill her children.

Prosecutors agreed to give Noe 20 years of probation, the first five of which would be served in home confinement and psychiatric analysis. She was required to undergo mental health treatment sessions with a psychiatrist to determine the cause of her repeated infanticide.

“It's important for the medical community and the legal community that she admit theses murders and ...something good will come out of the analysis,” said Deputy District Attorney Charles F. Gallagher.

“This is not one of those situations where we have a heart of a killer,” said defense attorney David Rudenstein.

“I have nothing to hide,” she said, “… [and] I will tell you everything I can possibly remember.”

Sentencing

Noe was sentenced to 20 years of probation with the first five years under house arrest.

Court TV coverage described that Noe would not spend any time in jail for the crime and would serve the first five years under home confinement and psychiatric analysis.

The sentencing also included that Noe must undergo mental health treatment sessions with a psychiatrist to determine the cause of her repeated infanticide.

Appeals

No appeals were described in the provided material.

Outcome

Noe’s guilty plea resolved the case.

Aftermath and related events

In September 2001, a study was filed with the court that stated Noe was suffering from mixed-personality disorder.

People

• Marie Noe — defendant; convicted of murdering eight of her children and pleaded guilty in June 1999 to eight counts of second-degree murder.
• Arthur Noe — husband of Marie Noe; not charged.
• Waneta Hoyt — New York woman whose case was referenced through The Death of Innocents.
• Lynne M. Abraham — district attorney mentioned in connection with the first-degree murder charge in August 1998.
• Charles F. Gallagher — deputy district attorney who commented on the importance of admission and analysis.
• David Rudenstein — defense attorney.
• Jay Feinschi — assistant district attorney who commented at a bail hearing and called Noe “as much a mass murderer as Ted Bundy.”
• Dr. Neil Kaye — forensic psychiatrist specializing in infanticide; commented on arrest timing.
• Dr. Halbert Fillinger — Montgomery County medical examiner referenced in relation to his suspicions and his work on prior autopsies.
• Dr. Marie Valdes-Dapena — referenced as a pediatric pathology expert and consultant.
• Joseph McGillen — investigator who spent extensive time trying to crack the Noe case.
• Remington “Rem” Bristow — investigator.
• Sergeant Larry Nodiff — Homicide Special Investigations Unit sergeant who reopened the investigation in the time period described.
• Dr. Joseph Spelman — medical examiner referenced in connection with conclusions and letters.
• Dr. Halbert Fillinger — assistant medical examiner referenced in autopsy work.
• Sister Victorine — supervisor in pediatrics at St. Joseph’s referenced in statements about Constance Noe.
• Sister Gemma — nursing colleague who provided statements about Marie Noe’s behavior during Constance Noe’s hospitalization.
• Dr. Columbus Gangemi — physician referenced in multiple medical episodes concerning later children.
• Dr. Salvatore Cucinotta — obstetric surgeon referenced regarding uterine rupture and hysterectomy.
• Dr. Patrick Pasquariello — pediatrician referenced as remembering delivery and early hospital care for Arthur Joseph Noe.
• Michelle McAuley — mentioned as contributing to Court TV reporting.
• The Associated Press — mentioned as contributing to reporting.

Timeline

• March 1998 — The author of the Philadelphia article turned over investigation results to the Philadelphia Police Department.
• August 1998 — Noe was charged with first-degree murder.
• June 28, 1999 — Marie Noe pleaded guilty to eight counts of second-degree murder.
• June 1999 — Noe was sentenced to 20 years of probation with the first five years under house arrest.
• September 2001 — A study was filed with the court stating Noe was suffering from mixed-personality disorder.

Children who died

Marie and Arthur Noe had ten children, all of whom died between the ages of 5 days and 14 months; eight died between 1949 and 1968 of mysterious causes attributed to SIDS, and two died of natural causes. The children were:

• Richard Allan Noe — March 7, 1949–April 7, 1949.
• Elizabeth Mary Noe — September 8, 1950–February 17, 1951.
• Jacqueline Noe — April 23, 1952–May 3, 1952.
• Arthur Joseph Jr. Noe — April 23, 1955–April 28, 1955.
• Constance Noe — February 24, 1958–March 20, 1958.
• Letitia Noe — stillborn, August 24, 1959; cause of death was umbilical cord knot.
• Mary Lee Noe — June 19, 1962–January 4, 1963.
• Theresa Noe — died in hospital, June 1963; cause of death was “congenital hemorrhagic diathesis.”
• Catherine E. Noe — December 3, 1964–February 24, 1966.
• Arthur Joseph Jr. Noe — July 28, 1967–January 2, 1968.

During the Caesarean birth of her last child, Noe suffered a uterine rupture and underwent a hysterectomy.

Other details

Insurance and adoption-related allegations

Investigators described that the Noes had taken out insurance policies on six children, and referenced that doctors and investigators attributed the deaths to SIDS during the period when the deaths occurred.

The material described adoption-related circumstances involving the possibility of placing a child with the Noes and investigation efforts connected to adoption inquiries.

Verbatim statements and quotes from proceedings and interviews

• Defense attorney David Rudenstein said: “This is not one of those situations where we have a heart of a killer.”
• At first questioning by police after Little Arty’s death, Noe said: “I have nothing to hide,” and “I will tell you everything I can possibly remember.”
• Arthur Noe said: “I've lived with this woman for 50 years. She was my life,” and “That woman was not capable of doing such a thing. She wouldn't harm a fly.”
• Noe stated: “They really couldn't prove I did any harm to the children,” and “Every one of them children didn't have a bruise, didn't have anything medically wrong.”

“They really couldn't prove I did any harm to the children,”
“Every one of them children didn't have a bruise, didn't have anything medically wrong.”

“I was very, I guess you would call it hard to teach,”
“I came down with scarlet fever, and I was one of the ones they experimented on, with different drugs. I guess it took a toll on my … um, my noodle,”
“and as I got older I got worse, trying to learn and stuff like that there — “

“After we were married, I would make her sit down and read the dictionary, and take the mathematics tables off the old copy books. Now, she can do a checkbook, she reads books.”

Medical examiner letters

The material included verbatim language from letters attributed to Dr. Joseph Spelman in response to comments Noe made to investigators McGillen and Bristow during a funeral-home viewing.

”You undoubtedly have read about the death of the tenth child in [the Noe] family. … This office has actively investigated several of these deaths. We have extensive files on the background of this family. We are not willing to declare with certainty that these children died natural deaths. ”In the event that thought is given to placing children under the care of the Noes, we would be glad to discuss our file and our thoughts in detail.”