United States v. Lyons, 695 F.2d 802 (4th Cir. 1982)

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US Court of Appeals for the Fourth Circuit - 695 F.2d 802 (4th Cir. 1982)

Argued Nov. 8, 1982. Decided Dec. 14, 1982

Michael Ian Gilbert, Hyattsville, Md., for appellant Lyons.

Richard D. Caplan, Hyattsville, Md. (Sanford Z. Berman, Pickett, Houlon & Berman, Hyattsville, Md., on brief), for appellant Royster.

Price O. Gielen, Asst. U.S. Atty., Baltimore, Md. (J. Frederick Motz, U.S. Atty., Barbara S. Sale, Asst. U.S. Atty., Baltimore, Md., on brief), for appellee.

Before WINTER, Chief Judge, CHAPMAN, Circuit Judge, and BUTZNER, Senior Circuit Judge.


Reginald Lyons and Willie Renaldo Royster appeal from the judgments entered upon their convictions for offenses involving the distribution of cocaine, asserting two grounds of reversible error. Their first contention is that the execution of a federal wiretap order by District of Columbia Metropolitan Police Department members of the federal Drug Enforcement Agency joint task force constituted a violation of Title III of the Omnibus Crime Control Act, requiring suppression of the intercepted phone calls. We disagree, and adopt on this issue the precise and well-reasoned opinion of the district court. United States v. Lyons, 507 F. Supp. 551, 556-61 (D. Md. 1981).

Defendants' second contention is that the admission at trial of evidence concerning their use of cocaine and negotiations concerning heroin to which defendant Lyons was a party was improper and prejudicial, in that the crime alleged involved the distribution of cocaine. We reject this argument. The evidence did show bad acts and other crimes, but its relevance outweighed its prejudicial effect. The evidence indicating use of cocaine to test the purity of the drug was an integral part of a cocaine distribution plan. Moreover, the evidence indicated that the defendants and a government witness distributed cocaine to one another for personal consumption. The reference to heroin was necessary to explain why Lyons had agreed to distribute cocaine to a government witness. We therefore find no error in the introduction of those statements.


Primary Holding

Insanity negates criminal liability if the defendant could not appreciate the wrongfulness of the conduct at the time that it happened.


Lyons argued in response to a charge of possession of narcotics that he was a drug addict. According to him, this meant that he had lost the ability to conform his conduct to the law. He was convicted after the judge ruled that this line of argument was impermissible.



  • Thomas Gibbs Gee (Author)

The defendant's argument resembles an insanity defense, which applies only if the defendant was unable to understand why his actions were wrong because of a mental disease or defect at the time that he was committing them. Insanity generally is no longer defined as an irresistible impulse, since the difference between an irresistible impulse and a decision to commit a crime is difficult to discern even for psychological experts. A defendant is not entitled to present an argument that is based on mere speculation.


  • Alvin Benjamin Rubin (Author)

The inability to conform one's conduct to the law inherently negates the mental state element that is required for a finding of guilt. Legal standards should not be abandoned only because they are hard to apply.

Case Commentary

The insanity defense has been applied in an increasingly narrow range of situations as courts have retreated from the sweeping "irresistible impulse" test and grown less sympathetic to defendants using this argument.

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