Commonwealth v. Lawson, 475 Mass. 806

Background

Defendant resisted arrest after officers told him he had an outstanding warrant; he pushed an officer, was taken to the ground, kicked an officer in the head, and flailed while handcuffed.
At the scene and at the hospital he exhibited manic, paranoid, and delusional behavior; emergency antipsychotic medication was given.
Defendant had an extensive history of serious mental illness (schizoaffective/bipolar spectrum), multiple commitments, and recent discontinuation/noncompliance with antipsychotic/mood-stabilizing medications before the incident.
At trial defendant presented a forensic psychologist who opined defendant lacked criminal responsibility at the time of the offense; the Commonwealth offered no rebuttal expert testimony and relied on circumstantial evidence and cross-examination.
The trial judge denied defendant’s motion for required findings of not guilty by reason of lack of criminal responsibility and convicted on multiple assault and resisting-arrest counts; defendant appealed directly to the SJC.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to disprove lack of criminal responsibility	Commonwealth: criminal responsibility need not be an element; may be proven by circumstances and conduct without expert rebuttal	Lawson: without expert rebuttal, judge must have relied on the "presumption of sanity," which alone cannot satisfy proof beyond a reasonable doubt	The court held the commonsense inference of sanity (formerly called the "presumption of sanity") cannot alone satisfy the Commonwealth's burden, but circumstantial evidence here sufficed to prove criminal responsibility beyond a reasonable doubt
Whether the "presumption of sanity" is a permissible presumption	Commonwealth argued jury may infer sanity from general probability	Defendant argued that inference is inadequate when defense evidence is presented	Court: the "presumption" is actually a commonsense inference, not a legal presumption, and it is too weak alone to meet the reasonable-doubt standard when defendant offers some evidence of lack of responsibility
Need for expert testimony to prove sanity	Commonwealth: expert proof not always required; circumstantial evidence can suffice	Defendant: without psychiatric rebuttal, conviction cannot stand	Court: expert testimony is not always required; where circumstantial and behavioral evidence is strong, Commonwealth may prevail without an expert; here evidence was sufficient
Prosecutor's argument at motion hearing	Commonwealth argued defendant understood actions and willfully declined meds	Defendant: prosecutor misstated the record and prejudiced the judge	Court: prosecutor’s inferences about understanding were fair; the remark about willful refusal to medicate did not prejudice the judge given defense correction at trial

Key Cases Cited

Commonwealth v. Keita, 429 Mass. 843 (1999) (burden on Commonwealth to prove criminal responsibility when defendant proffers sufficient evidence of lack of responsibility)
Commonwealth v. Kostka, 370 Mass. 516 (1976) (criminal responsibility not an element; discussion of the so-called presumption of sanity)
Commonwealth v. Smith, 357 Mass. 168 (1970) (court historically allowed juries to weigh general probability of sanity against psychiatric testimony)
Commonwealth v. McHoul, 352 Mass. 544 (1967) (describes Commonwealth’s burden to prove absence of mental disease or defect and capacity to appreciate or conform)
Commonwealth v. Cullen, 395 Mass. 225 (1985) (sanity may be inferred from facts underlying the crime)
Commonwealth v. Ricard, 355 Mass. 509 (1969) (absence of motive and the nature of the act support claim of lack of criminal responsibility)
Commonwealth v. Pike, 430 Mass. 317 (1999) (contrary defendant evidence must be "conclusively incorrect" to affect sufficiency review)
In re Winship, 397 U.S. 358 (1970) (constitutional requirement that prosecution prove elements of crime beyond reasonable doubt)