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United States v. Lyons | 731 F.2d 243 (1984)
In the late 1970s, John Hinckley attempted to assassinate then-president Ronald Reagan to gain the respect and love of actress Jodie Foster. At Hinckley’s trial for attempted murder, he asserted an insanity defense under the Model Penal Code, or MPC, resulting in his acquittal. This result sparked outrage across the country and lead to sweeping reforms to the insanity defense. In the 1984 case United States versus Lyons, the Fifth Circuit considered whether a defendant could assert the insanity defense under the MPC’s test based on his drug addiction.
Robert Lyons was indicted in federal district court on twelve counts of knowingly and intentionally securing controlled narcotics in violation of federal law. Prior to trial, Lyons submitted evidence that in 1978 he became addicted to various narcotics that he used for pain management. Based on this evidence, Lyons planned to present expert witnesses who would testify that his drug addiction affected his brain and that, consequently, Lyons lacked the capacity to conform his conduct to the requirements of the law and was therefore insane.
Additionally, prior to trial, the United States submitted a motion in limine asking the court to exclude any evidence of Lyon’s drug addiction because it couldn’t constitute a mental disease sufficient to support an insanity defense. The district court agreed and granted the motion. Following trial, Lyons was convicted. Subsequently, Lyons appealed to the Fifth Circuit.
On appeal, a panel on the Fifth Circuit reversed and remanded the case for a new trial, holding that it was the jury’s responsibility to decide whether an involuntary drug addiction could constitute a mental disease sufficient to support an insanity defense. Based on the request of the United States, the Fifth Circuit agreed to rehear the case en banc, or before the entire court.
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