Also known as: lunacies · insanity · mental unsoundness
Written by attorneys · grounded in primary & secondary sources — see below
A condition of mental unsoundness or insanity.
Luke Latham, an adult plant manager with a documented psychotic disorder, directed workers to skip a mandatory pressure test to meet a deadline. The vessel ruptured and damaged neighboring property. Lake Assembly sued Latham for negligence. Latham's mental condition supplied no defense because an adult actor remains subject to the unmodified reasonable-person standard.
Lillian Locke was arrested, given Miranda warnings, and questioned about her mental state. She remained silent. At trial she asserted a lunacy defense. The prosecutor urged the jury to infer from her silence that she had appreciated the wrongfulness of her conduct. The argument violated due process because post-warning silence may not rebut an insanity claim.
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Lorenzo Lugo was indicted for a federal offense. After discovery closed he filed a written notice asserting a lunacy defense based on recent hospitalization. The government moved to preclude the defense. Because the notice was untimely and no good cause was shown, Lugo could not rely on the defense at trial.
Laura Lewis was charged with murder. She offered evidence of longstanding delusions to support a lunacy defense. The trial court instructed the jury that every person is presumed sane and that the defendant bears the burden of proving otherwise. Lewis therefore had to overcome the presumption to obtain an acquittal.
Latoya Lane was convicted of a felony. The sentencing judge found, by a preponderance of the evidence, that Lane's lunacy made her a continuing danger and imposed an enhanced term. Lane objected that the finding had to be made by a jury beyond a reasonable doubt. The enhancement therefore required a jury determination of the mental-condition fact.
Lamar Lewis was charged with homicide. He raised a lunacy defense and the state sought to place on him the burden of disproving malice. The court held that the prosecution must prove every element of the offense beyond a reasonable doubt. Lewis therefore could not be required to disprove an element even while asserting the defense.
No. Unless the actor is a child, insanity or other mental deficiency does not relieve the actor from liability for conduct that does not conform to the standard of a reasonable person under like circumstances. The rule preserves an objective standard and prioritizes compensation for injured third parties.
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No. Once Miranda warnings are given, the government implicitly assures the suspect that silence carries no penalty. Due process therefore forbids the state from using post-warning silence as substantive evidence to rebut or counter a claim of lunacy.
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The defendant cannot rely on the defense. Federal Rule of Criminal Procedure 12.2(a) requires written notice within the time for pretrial motions. Failure to provide notice bars the defense unless the court finds good cause for a late filing.
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The defendant bears the burden of proving the affirmative defense of insanity. The prosecution retains the burden of proving every element of the offense beyond a reasonable doubt, but a state may constitutionally assign the insanity burden to the defendant.
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…Oregon's requirement that the defendant, rather than the State, bear the burden on factual determination of defendant's insanity). Patterson is important because it plainly refutes the Court's expansive reading of Mullaney . Indeed, the defendant in Patterson characterized Mullaney exactly as the Court has…