Criminal Law > Criminal Law Keyed to Kadish > Exculpation
United States v. Lyons
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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.
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.
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?
No. Judge Gee delivered the opinion of the court. Although addiction is not a mental disease, the addiction itself may cause actual physical damage to the brain resulting in a “mental disease or defect” of the brain. Defendant rightfully sought to offer such evidence to the jury. Although the court no longer recognizes the volitional prong under the insanity defense, defendant should be afforded the opportunity to offer such evidence in an attempt to satisfy the cognitive prong.
We hold that 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. We reach this conclusion for several reasons. First, a majority of psychiatrists believe there are not enough accurate scientific bases for measuring a person’s capacity for self-control. Secondly, the risks of fabrication in administering the insanity defense are greatest when the experts and the jury are asked to speculate about the defendant’s capacity to control himself. In addition, testimony concerning volition is more likely to confuse the jury than testimony about an appreciation for the wrongfulness of an act. Finally, the requirement of proof beyond a reasonable doubt makes it an almost improbable task with regard to the present state of medical knowledge.
Judge Rubin and Judge Tate dissenting. An adjudication of guilt is not only a factual determination but a moral judgment that an individual is to blame. The court’s decision rests on its desire to redefine insanity and to narrow the defense on policy considerations. Pleas of insanity are rarely successfully made and many do not even go to trial. There is a perception that an individual who successfully pleads insanity is released form custody. In almost every case, the individual is hospitalized and evaluated for dangerousness.
The proper inquiry under either branch of the insanity test is a subjective one focusing on the defendant’s state of mind. Our duty to investigate defendant’s state of mind is not based on expert testimony, but the ethical tenet that his mental state is a vital aspect of his blameworthiness. The availability of expert testimony and probative value of such testimony are evidentiary problems that can fit within the existing test.
The court concludes that under the law, all criminal impulses should be treated as resistible. They reached this assumption based on several things. First, a majority of psychiatrists believe they do not possess enough accurate scientific bases for measuring an individual’s capacity for self-control. In addition, the risks of fabrication in administering the insanity defense are greatest when the experts and the jury are asked to speculate whether the defendant had the ability to control himself. Furthermore, there appears to be an overlap between a psychotic person’s inability to understand and his ability to control his behavior. Finally, current case law requires that such proof be made beyond a reasonable doubt. This task is quite daunting in light of the present unclear state of medical knowledge.