United States v. Rickert, No. 11-1675 (8th Cir. 2012)
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Defendant pleaded guilty to one count of bank fraud. Defendant subsequently filed a motion for a competency hearing and evaluation pursuant to 18 U.S.C. 4241. The district court denied the motion and sentenced Defendant to 72 months' imprisonment. Defendant appealed the denial of his motion for a competence determination and his sentence. The Eighth Circuit Court of Appeals affirmed, holding that the district court (1) did not commit reversible error in refusing to order a competency hearing; (2) did not commit procedural errors at sentencing; (3) did not err in denying Defendant a downward adjustment for acceptance of responsibility; and (4) did not improperly increase Defendant's sentence for the purpose of promoting rehabilitation.
Court Description: Criminal case - Criminal law and sentencing. District court did not abuse its discretion by denying defendant's motion for a competency exam as the information provided to the court in support of the motion was not so strong as to overcome the district court's reservations about defendant's credibility and the court's own observations that defendant was lucid and intelligent at sentencing; district court did not err in imposing a two-level enhancement for obstruction of justice under Guidelines Sec. 3C1.1 where defendant provided the court with fraudulent letters with his sentencing memorandum; nor did the court err in denying his request for a three-level reduction for acceptance of responsibility under Guidelines Sec. 3E1.1 because of his attempt to obstruct justice; record does not support defendant's claim that the court improperly imposed or lengthened his sentence to promote his rehabilitation.
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