United States v. Brennan, No. 19-262 (2d Cir. 2019)Annotate this Case
The Second Circuit affirmed the district court's order committing defendant to the custody of the Attorney General under 18 U.S.C. 4241(d) for psychiatric treatment and evaluation. Defendant alleged that the district court's order violated his due process rights because a forensic psychologist stated that his disorder was degenerative and would not significantly improve with treatment.
The court held that, under 18 U.S.C. 4241 et seq., commitment to assess future competency is mandatory, and only the district court, and not a forensic psychologist, can determine whether defendant will regain competency in the foreseeable future. In the absence of such a decision, the court held that defendant's commitment to the custody of the Attorney General for treatment and further evaluation was reasonably related to determining whether defendant will regain competency in the foreseeable future. Therefore, the court held that the district court constitutionally applied section 4241(d)'s commitment procedures to defendant.