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United States v. Sweeton

United States District Court, E.D. Kentucky, Southern Division

July 7, 2017




         Defendant Jamie Sweeton is charged with conspiracy to distribute oxycodone in violation of 21 U.S.C. §§ 841(a)(1) and 846, and aiding and abetting in the burglary of a pharmacy in violation of 18 U.S.C. §§ 2 and 2118(b), both Class C felonies. He has pled not guilty (D.E. 53), and his trial is currently scheduled for August 22, 2017. D.E. 140.

         On April 4, 2017, Defendant, through counsel, filed a motion for a competency evaluation. D.E. 124. At the motion hearing on April 7, 2017, the Court granted the motion, ordered an evaluation in a custodial setting, and Defendant was remanded to the custody of the United States Marshal. D.E. 126; 127. On April 11, 2017, the Court, upon the required findings, ordered the psychiatric or psychological examination pursuant to 18 U.S.C. § 4247(b) to be performed at the Federal Medical Center-Lexington (“FMC-Lexington”) in Lexington, Kentucky. D.E. 129. Defendant was evaluated at FMC-Lexington from April 17, 2017, through June 1, 2017. D.E. 153 at 2. All parties had access to the Psychiatric Report (“the Report”) issued by Dr. Judith Campbell, Ph. D., following this evaluation, in which she found Defendant competent to stand trial. Id. at 9.

         On July 6, 2017, the Court conducted a competency hearing in this matter, per 18 U.S.C. §§ 4241 and 4247(d), in London, Kentucky. D.E. 158. During that hearing, the parties stipulated to the admissibility of the Report, as well as to the Report's findings. The parties also waived introduction of other proof and argument in opposition, and waived the right to examine or cross-examine the evaluator.

         Section 4241 codifies the competency principles of Dusky v. United States, 362 U.S. 402 (1960). To be competent under this standard, a defendant must have “sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding” and “a rational as well as a factual understanding of the proceedings against him.” Dusky, 362 U.S. at 402; see also 18 U.S.C. § 4241(a) (phrasing the test as whether a defendant is “unable to understand the nature and consequences of the proceedings against him or to assist properly in his defense”). 18 U.S.C. § 4247(d) governs the competency hearing, and assures certain trial-type rights. These include the right to confront and cross-examine witnesses, and the right to participate in the hearing. See id.; see also 18 U.S.C. § 4241(c) (referring to the hearing procedures outlined in section 4247(d)).

         Ultimately, per section 4241(d), a defendant is not competent if, “after the hearing, the court finds by a preponderance of the evidence that the defendant” meets the incompetency definition of section 4241(a). This framework does not dictate which party bears the burden, which has led to disagreements among the Circuits. See United States v. Carter, No. 1:12-CR-29, 2013 WL 6668715, at *11 (E.D. Tenn. Dec. 18, 2013) (compiling cases).[1] Here, the proof is not in any way disputed, and the Court need not resolve the burden allocation question. See Medina v. California, 505 U.S. 427, 449 (1992) (indicating that argument over burden, in competency context, only matters in “narrow class” of cases where the proof is “in equipoise”).

         Defendant stipulated as to both the admissibility and the substance of the Report. Accordingly, the only proof concerning Defendant's competency is the expert analysis of Dr. Campbell. The Report reflects personal observation, a review of Defendant's available medical history and status, sufficient psychological testing, and a thorough assessment of Defendant's abilities in light of the applicable competency standards. Dr. Campbell analyzed Defendant's history, course of evaluation, and testing performance. She directly observed Defendant via interviews and subjected him to a battery of psychological testing. Dr. Campbell spoke with the prosecutor and defense counsel. She also secured and reviewed some legal documents and medical records, including mental health records from Centerstone Community Mental Health Care Center.

         Dr. Campbell's report is a thorough and comprehensive assessment of Defendant's history, mental and psychiatric condition, and circumstances. Notably:

(1) The Report indicates that in spite of previous reports of anxiety, Defendant was not exhibiting any signs or symptoms of acute psychological distress at the time of the evaluation. D.E. 153 at 4.
(2) Defendant's mental condition remained stable over the course of the evaluation, and he did not display aggressive or bizarre behavior or any behavioral management problems suggestive of mental illness. Id.
(3) Defendant's performance on the Wechsler Adult Intelligence Scale-Fourth Edition (“WAIS-IV”) indicates that he has some mild cognitive limitations. Id. at 5. Overall, the results of the psychological testing and clinical interviews with Defendant during the evaluation “suggest some cognitive limitations, but do not support a finding of severe mental illness or mental defect sufficient to preclude his ability to proceed competently at this time.” Id. at 6.
(4) Defendant's mental status examinations “revealed an oriented, logical, and rational individual who was cooperative, polite, and well-mannered during interviews and testing sessions.” Id.
(5) Although his vocabulary is limited, Defendant was able to discuss the case in “a rational and reality-based manner.” Id. Additionally, he did not display any symptoms of a formal thought disorder. Id.
(6) Defendant did appear to be suffering symptoms commonly associated with depression. Id. at 7. He showed “no signs of severely depressed mood over the course of the evaluation as he did not evidence feelings of pervasive worthlessness, or diminished appetite characteristic of ...

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