United States v. Garza, No. 12-10294 (9th Cir. 2014)
Annotate this CaseDefendant appealed his conviction and sentence for receipt or distribution and possession of child pornography. At issue was whether the district court plainly erred by failing to sua sponte convene a hearing on defendant's competency. The court concluded that there is no substantial evidence such that a reasonable judge would harbor a genuine doubt about defendant's competency where defendant's medical evidence was not strong and where there was no clear connection between any mental disease or defect and any failure on defendant's part to understand the proceedings or assist in his own defense. The court rejected defendant's arguments under 18 U.S.C. 4247 and 4241. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal Law. Affirming a criminal judgment, the panel held that the district court did not plainly err by failing to sua sponte convene a hearing on the defendant’s competency. The panel held that there is no substantial evidence that a reasonable judge would harbor a genuine doubt about the defendant’s competency, where the defendant’s medical history evidence isn’t strong and there is no clear connection between the defendant’s putative dementia and any negative impact on his ability to understand the proceedings or assist in his defense. The panel rejected the defendant’s attempt to reach plain error in reliance on 18 U.S.C. § 4241(a), requiring competency hearings on reasonable cause, and 18 U.S.C. § 4247(b), governing commitment for the purposes of an examination.
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