United States v. Wayda, No. 19-7754 (4th Cir. 2020)
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The Government initiated a civil commitment proceeding under 18 U.S.C. 4248, seeking the commitment of appellee to the custody of the Attorney General as a "sexually dangerous person."
The Fourth Circuit affirmed the district court's dismissal of the section 4248 civil commitment certification as untimely. The court held that once the Maryland district court determined appellee was incompetent to stand trial, appellee could remain committed to the Attorney General for only an additional reasonable period of time until his charges were disposed of in accordance with law. Absent a creditable explanation of the reasonableness of appellee's commitment post-December 2018 -- two years after his initial commitment and six full months after the Unrestorability Determination -- the statutory language and the court's precedent in United States v. Searcy, 880 F.3d 116, 122 (4th Cir. 2018), and United States v. Timms, 664 F.3d 436, 451–52 (4th Cir. 2012), compel the court to hold that appellee could no longer be considered legitimately committed to the Attorney General's custody in June 2019.
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