United States v. McKown, No. 18-20467 (5th Cir. 2019)
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The Fifth Circuit held that the order committing defendant for a maximum of four months accords with due process. The court held that, even where the medical evidence indicates that the defendant's condition is permanent, temporary hospitalization bears some reasonable relation to the purpose for that confinement.
In this case, defendant was charged with threatening to assault and murder two federal employees. The district court found that he lacked capacity to stand trial and ordered his temporary hospitalization to determine whether he might regain competency in the foreseeable future. The court joined its sister circuits in holding that such mandatory, limited confinement accords with due process.
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