US v. Melania Corcino, No. 10-4107 (4th Cir. 2011)
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UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 10-4107 UNITED STATES OF AMERICA, Plaintiff - Appellee, v. MELANIA CORCINO, Defendant - Appellant. Appeal from the United States District Court for the Eastern District of North Carolina, at Raleigh. Terrence W. Boyle, District Judge. (5:05-cr-00260-BO-2) Submitted: March 17, 2011 Decided: April 13, 2011 Before SHEDD, AGEE, and WYNN, Circuit Judges. Affirmed by unpublished per curiam opinion. Raymond J. Rigat, Washington, DC, for Appellant. George E. B. Holding, United States Attorney, Matthew L. Fesak, Anne M. Hayes, Assistant United States Attorneys, Raleigh, North Carolina, for Appellee. Unpublished opinions are not binding precedent in this circuit. PER CURIAM: Melania Corcino pled guilty to conspiracy to commit sex trafficking of minors, sex trafficking through coercion, and interstate transportation of persons with intent to engage in prostitution, in violation appeal, she challenges district court erred whether she was medical evidence of her by 18 U.S.C. § 371 conviction, failing to competent to enter showed that she (2006). claiming inquire the the into when post-plea from suffered psychological problems at the time of the plea. that sponte sua plea On untreated We affirm. We review for abuse of discretion a defendant s claim that the hearing. 2007). court s district court should have ordered a competency United States v. Banks, 482 F.3d 733, 742-43 (4th Cir. Under this exercise of standard, we discretion, must determine considering facts, was arbitrary or capricious. the whether law and the the United States v. Mason, 52 F.3d 1286, 1289 (4th Cir. 1995). The district court should hold a competency hearing when it has reasonable cause to believe that a defendant may suffer from a mental disease or defect that interferes with his ability to understand proceedings against defense. 18 him U.S.C. the or nature to § 4241(a) and assist consequences properly (2006); United Moussaoui, 591 F.3d 263, 291 (4th Cir. 2010). 2 in of the his own States v. To determine whether reasonable cause exists, the district court should consider any evidence of irrational behavior, the defendant s demeanor at defendant s trial, and medical competence. Mason, opinions 52 F.3d concerning at 1290. the [T]he presence of some degree of mental illness is not to be equated with incompetence. . . . 659 (4th Cir. 1969). Hall v. United States, 410 F.2d 653, Instead, the legal test for competency is whether the defendant has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and whether he has a rational as well as factual understanding of the proceedings against him. Dusky v. United States, 362 U.S. 402 (1960). Our review of the record leads us to conclude that the district court did not abuse its discretion by failing to sua sponte conduct a retrospective competency hearing to determine if Corcino was competent to enter the plea. The medical evidence in the record, including that of Corcino s own expert, did not establish reasonable cause to believe that Corcino, at the time of the plea, was unable to assist her attorney or understand the consequences of the proceedings Accordingly, we affirm her conviction. against her. We dispense with oral argument because the facts and legal contentions are adequately 3 presented in the materials before the court and argument would not aid the decisional process. AFFIRMED 4
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