United States v. Lyons
706 F.2d 321
Brief Filed: 11/83
Court: United States Court of Appeals for the Fifth Circuit
Year of Decision: 1984
Read the full-text amicus brief (PDF, 891KB)
Whether evidence of drug addiction should be admitted when the defendant raises an insanity defense
Defendant Lyons was indicted for narcotics violations. At trial, he attempted to rely on an insanity defense and present testimony that he lacked a substantial capacity to conform his conduct to the requirements of the law due to his drug addiction. The district court excluded any evidence of Lyon's addiction. A panel of the U.S. Court of Appeals for the Fifth Circuit reversed holding that it was the jury's responsibility to decide whether involuntary drug addiction could be "a mental disease or defect" for purposes of elements of the insanity defense. The Fifth Circuit agreed to a rehearing en banc and invited APA and others to file amicus briefs in the case concerning whether drug addiction was "a mental disease or defect" for purposes of elements of the insanity defense.
APA's brief argued that: (1) scientific evidence supported defendant's contention that the drugs prescribed by his physicians were highly addictive narcotic opiates; (2) although scientific evidence does not clearly indicate whether drug addiction itself is a mental disease or defect, evidence of a defendant's drug addiction should not automatically be excluded in all cases; (3) while neither physiological nor sociological theories completely explain addiction and do not clearly indicate whether addiction itself is a mental disease or defect, they are the most widely accepted explanations of addiction and evidence of addiction may be relevant to an insanity defense; and (4) scientific evidence supported defendant's argument that drug addiction effects the capacity to conform one's own conduct to the requirements of law.
The Fifth Circuit, en banc, held that mere addiction to narcotics — whether acquired voluntarily or involuntarily, without other physiological or psychological involvement — cannot be considered a mental disease or defect for purposes of the insanity defense. It reversed its decision in Blake v. United States, 407 F. 2d 908 (5TH Cir. 1969) and held that the volitional prong of the ALI insanity rule would no longer be a basis for asserting the insanity defense.