United States v. Mark Steffes, No. 17-2673 (8th Cir. 2018)
Annotate this CaseCourt Description: Per Curiam - Before Shepherd, Melloy and Grasz, Circuit Judges] Criminal case - Criminal law. In this challenge to a Sell order regarding defendant's involuntary medication, the parties notified the court at oral argument of changed circumstances, and the matter is remanded for the limited purpose of allowing the district court to review the changed circumstances to determine if its Sell order is still necessary and appropriate. The court retains jurisdiction over the appeal during the limited remand.
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 17-2673 ___________________________ United States of America lllllllllllllllllllllPlaintiff - Appellee v. Mark Allan Steffes lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the Northern District of Iowa - Ft. Dodge ____________ Submitted: May 16, 2018 Filed: June 7, 2018 [Unpublished] ____________ Before SHEPHERD, MELLOY, and GRASZ, Circuit Judges. ____________ PER CURIAM. Mark Allan Steffes (“Steffes”) appeals from the district court’s order granting the United States of America’s (the “Government’s”) motion to involuntarily medicate Steffes to render him competent to stand trial. This Court has appellate jurisdiction over certain collateral orders, including “Sell” orders regarding involuntary medication of criminal defendants for purposes of trial competency. See Sell v. United States, 539 U.S. 166, 176–77 (2003). At oral argument, the parties notified this Court of changed circumstances. During the pendency of this appeal, a clinical psychologist at the United States Medical Center for Federal Prisoners (“USMCFP”) informed the district court that Steffes met the criteria for “grave disability” and that USMCFP began involuntarily medicating him for his own safety. The Government may, after following certain procedures, involuntarily medicate a defendant to reduce the danger he poses to himself. See Washington v. Harper, 494 U.S. 210, 225–26 (1990). In addition, the need for a Sell order may disappear after involuntary medication on other grounds. See Sell, 539 U.S. at 183. A limited remand is required in this case to allow the district court to review the changed circumstances in the first instance. Accordingly, we remand this case to the district court for the limited purpose of addressing whether the Sell order it entered is still necessary and appropriate in light of the changed circumstances. We retain jurisdiction over the appeal during this limited remand. See 28 U.S.C. § 2106 (stating the authority of appellate courts to “require such further proceedings to be had as may be just under the circumstances”). ______________________________ -2-
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