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.