United States v. Dahl, No. 14-3588 (8th Cir. 2015)
Annotate this CaseDefendant pleaded guilty to drug offenses and subsequently appealed the denial of his motion seeking a psychological examination and competency hearing. The court found no abuse of the district court's discretion because there was no reasonable cause to believe that defendant was incompetent. In this case, the medical reports indicated physical injury including a brain injury that resulted in "mild cognitive impairment," but the medical reports provided no indication that defendant was incapable of understanding the nature or consequences of the legal proceedings. Further, defendant's extensive participation at his hearings showed he understood the nature and consequences of the proceedings. Accordingly, the court affirmed the judgment.
Court Description: Melloy, Author, with Loken and Gruender, Circuit Judges] Criminal case - Criminal law. The district court did not err in denying defendant's post-plea motion for a psychological exam and competency hearing based on its determination that there was no reasonable cause to believe defendant was incompetent; while the defendant had some memory lapses attributable to a brain injury and drug use, the medical reports provided no indication that he was incapable of understanding the nature or consequences of his legal proceedings, a point underscored by his extensive participation at the hearings.
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