United States v. Thomas, No. 18-3393 (8th Cir. 2020)
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Thomas was charged with a 10-year conspiracy involving kidnapping, forced labor, hate crimes, and racketeering-related violent crimes. The court rejected his guilty plea and ordered competency restoration under 18 U.S.C. 4241(b). Thomas was evaluated at a Medical Center for Federal Prisoners. Clinical Psychologist Chavez concluded Thomas was unlikely to become competent in the foreseeable future; 18 U.S.C. 4246(d) required commitment if, due to Thomas's mental deficiencies, his release would create a substantial risk of bodily injury or serious property damage. A Risk Assessment Panel diagnosed Thomas with an unspecified neurocognitive disorder, borderline intellectual functioning, and adult antisocial behavior, finding that Thomas “show[ed] a pattern of violating the rights of others,” and had previously been convicted of sexual assault, and implied that his professional boxing career suggested violent tendencies. The Panel explained that Thomas was easily manipulated by his domestic partner (the conspiracy’s ringleader). Thomas’s denials of past violence indicated a lack of empathy. The court granted Thomas’s request for an independent examination. Clinical Psychologist DeMier largely agreed with the diagnosis but concluded that Thomas’s dangerousness primarily stemmed from his manipulability, not his mental defects and did not warrant commitment.
The court noted Chavez and the Panel spent significantly more time evaluating Thomas and because DeMier’s opinion was inconsistent. Thomas was committed to the Attorney General’s custody. The Eighth Circuit affirmed. That DeMier’s “less-than-robust opinion” is contrary to the court’s conclusion does not warrant clear-error reversal.
Court Description: [Grasz, Author, with Shepherd and Kobes, Circuit Judges] Civil Commitment - 18 U.S.C. Section 4246. The district court did not err in giving greater weight to the opinions of the government's experts based on its conclusion that they spent more time with him and knew more about him than Thomas's expert; further, the court explained that the primary reason for ordering commitment was the weakness of Thomas's expert's testimony and not the simple fact that the government's experts spent more time with him; nor did the district court misinterpret the testimony and opinion of defendant's expert; commitment order affirmed.
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