Commonwealth v. LawsonAnnotate this Case
After a trial, Defendant was found guilty of two counts of assault and battery on a public employee, and one count each of assault and battery by means of a dangerous weapon, assault by means of a dangerous weapon, and resisting arrest. Defendant appealed, arguing that the trial judge erred in denying his motion for required findings of not guilty by reason of lack of criminal responsibility. Specifically, Defendant argued that the trial judge must have relied on a “presumption of sanity” because the evidence did not support a finding of criminal responsibility beyond a reasonable doubt. The Supreme Court affirmed, holding (1) although the Commonwealth may not rely on the so-called “presumption of sanity” to establish criminal responsibility, the Commonwealth may rely on the circumstances of the offense to prove the defendant’s criminal responsibility; and (2) the evidence in this case was sufficient to allow a reasonable finder of fact to find that Defendant was criminally responsible at the time of the offenses.