A Vermont woman convicted of killing three relatives and a social worker should never have been released early from an involuntarily hospitalization, her lawyer said ahead of next week's sentencing.

David Sleigh wrote in court documents this week that Jody Herring's "reckless and negligent" early release from a 90-day mental health hospitalization was a factor in her having a psychotic break.

On the day of the shooting of social worker Lara Sobel outside her office in Barre, "Jody Herring should have remained involuntarily hospitalized for the mental health crisis she was in the midst of, as she was clearly a danger to herself and to others," Sleigh wrote in arguing for leniency in her sentencing.

A spokeswoman for Rutland Regional Medical Center said Friday she cannot comment on the care of a patient or open legal matters.

Vermont's attorney general could not immediately be reached for comment Friday, a state holiday.

In a plea deal, Herring admitted that on Aug. 7, 2015, she shot and killed social worker Lara Sobel in Barre. She also admitted shooting two cousins, Regina Herring and Rhonda Herring, and her aunt Julie Falzarano at their Berlin, Vermont, home. Police said she believed her relatives had played a role in her losing the custody of her 9-year-old daughter.

The plea deal called for a sentence of 20 years to life on the second-degree murder convictions, to be served concurrently. She could be sentenced to life without parole on the first-degree murder conviction. Her five-day sentencing hearing starts Monday.

Sleigh wrote that a variety of factors combined to cause Herring to have a psychotic break. They included decades of brutal inter-generational abuse and familial dysfunction; Herring's history as a victim of severe physical, emotional and mental abuse; the loss of custody of her two daughters to her mother; her repeated attempts to reach out for help for her daughters and herself; her unfair treatment in family court which led to the unjustified loss of her third daughter and her subsequent mental breakdown, followed by the early release from the hospital, Sleigh said.

He said the hospital released her early, despite knowing of her highly volatile unstable mental state in order to try to cover up two errors: one, that the family court had been notified of her hospital stay despite her written denial of consent for that to happen and because a man had broken into her locked room and tried to get into bed with her and used her bathroom.

"If Rutland Regional Medical Center and the Vermont Attorney General's office had done the right thing, Jody Herring would have been locked up involuntarily in a psychiatric facility, in Rutland, Vermont, on Aug. 7, 2015," he said.