United States v. Lyons
731 F.2d 243, 739 F.2d 994 (1984)
Lyons was suffering some pains
and got some prescription painkillers. He ended up getting addicted to
them. After the prescriptions ran out, he obtained the drugs illegally.
Lyons was arrested and charged
with possession of illegal drugs.
The Trial Court convicted
Lyons of possession of illegal drugs. He appealed.
Lyons argued the defense of insanity. He claimed that the drug addiction affected
his brain both physiologically and psychologically and that as a result
he lacked substantial capacity to conform his conduct to the requirements
of the law.
Basically, Lyons argued that
he knew the drugs were illegal, he just couldn't help himself.
The Appellate Court upheld the
conviction.
The Appellate Court found
that drug addiction, without more, is not a 'mental disease or defect'
and so cannot serve as a basis for an insanity defense.
The Appellate Court found
that the insanity defense is only
applicable in cases where, as a result of mental disease or defect, a
defendant is unable to appreciate the wrongfulness of his conduct.
The Court overruled their
previous decision in Black v. United States (407 F.2d 908 (1969)), where they held that insanity
could be asserted in cases "where the defendant lacks the capacity
to conform one's conduct to the requirements of the law."
The Court found that it was
impossible to determine if a person had the ability to control their
impulses, so the old standard was unworkable. It was easier to show
that someone could not appreciate the wrongfulness of their actions.