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United States v. Lyons

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Bloomberg Law

Citation. 10-10159-PBS., 2012 BL 112527, 2012 ILRC 1831 (D. Mass. May 04, 2012)

Brief Fact Summary. Defendant, Robert Lyons was indicted on twelve counts of securing controlled narcotics. Lyons claimed his drug addiction was a mental disease within the definition proscribed in the insanity defense. The trial court excluded evidence pertaining to this issue and he was convicted.

Synopsis of Rule of Law. A defendant in a criminal case is not guilty by reason of insanity if at the time of the conduct, as a result of mental disease or defect, he is unable to appreciate the wrongfulness of his conduct.


Facts. Lyons was convicted of twelve counts of knowingly and intentionally securing controlled narcotics. During trial, Lyons claimed his drug addiction was a mental disease within the definition proscribed in the insanity defense. He offered evidence that in 1978 he became addicted to several prescription drugs given to him for pain relief from ailments. In addition, Lyons sought to present expert witnesses who would testify that his drug addiction changed the physiology and psychology of his brain resulting in an incapacity to conform his conduct to the requirements of the law. The trial court, however, excluded the proffered evidence.

Issue. Does the existing insanity defense standard of a “lack of capacity to conform one’s conduct to the requirements of the law” coincide with current medical and scientific knowledge?

Content Type: Brief


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