United States v. Dalasta, No. 16-1818 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed a commitment order, holding, pursuant to the plain language of 18 U.S.C. 4241(d), that once a defendant is found incompetent to stand trial, a district judge has no discretion in whether or not to commit him. The Eighth Circuit agreed with its sister circuits that section 4241(d) imposes a mandatory duty to commit a defendant who is found incompetent to the custody of the Attorney General, even if there is undisputed medical evidence that the defendant cannot be restored to competency. In this case, defendant's firearms offense and need for constant care by aging parents strongly indicated that the assistance of BOP experts would be needed in the section 4246 analysis. The Eighth Circuit also held that the limited commitment mandated by section 4241(d) complied with due process limitations outlined in Jackson v. Indiana, and the Attorney General, not the district court, has the discretion to order a non-custodial alternative.
Court Description: Loken, Author, with Beam and Benton, Circuit Judges] Criminal case - Criminal law. Once a defendant is found incompetent to stand trial, a district judge has no discretion in whether or nor to commit him, as 18 U.S.C. Sec. 4241(d) imposes a mandatory duty to commit a defendant who is found incompetent to the custody of the Attorney General, even if there is undisputed medical evidence that the defendant cannot be restored to competency; commitment under such circumstances is not, as defendant argues, an absurd result as the commitment gives the Attorney General's medical experts time to evaluate the defendant's continuing dangerousness if he were released after a 4246(a) hearing; such a commitment does not violate defendant's liberty interests under the due process clause; it is up to the Attorney General, not the court, to determine whether a non-custodial alternative better suits the situation.
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