Two patients showed inability to voluntarily close the eyes. They had normal reflex closure and slept with their eyes closed. Comprehension was normal. Both had bilateral frontal lesions. This symptom is probably indicative of fundamental motor dysfunction, rather than apraxia as has previously been suggested.
Lessell S. Supranuclear Paralysis of Voluntary Lid Closure. Arch Ophthalmol. 1972;88(3):241-244. doi:10.1001/archopht.1972.01000030243002