Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

United States v. Koehler

United States District Court, E.D. Kentucky, Central Division, Lexington

March 18, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
SCOTT KOEHLER, Defendant.

          MEMORANDUM OPINION AND ORDER

          Joseph M. Hood Senior U.S. District Judge

         On March 18, 2019, Defendant Scott Koehler appeared before the Court for a competency hearing. Koehler was represented by court-appointed counsel at the hearing. After considering the evidence, including reports of competency evaluations submitted by the Defendant, the Court found that Koehler is suffering from a mental disease or defect that makes him unable to understand the consequences and nature of the criminal proceedings and makes him unable to assist his attorney, which renders Koehler incompetent to stand trial at this time. As a result, Koehler shall be COMMITTED to the custody of the United States Attorney General for a reasonable period, not to exceed four months, to determine whether there is a substantial probability that Koehler's condition will improve in the foreseeable future such that he may stand trial.

         I. Procedural History

         Defendant Scott Koehler is charged with two counts of unlawful possession of a firearm by a prohibited person in violation of 18 U.S.C. §§ 922(g)(8), (g)(9). [DE 1]. Koehler's former court-appointed attorney, Benjamin D. Allen, moved for a competency evaluation. [DE 18]. Allen stated that he had doubts about whether Koehler could understand the charges contained in the indictment. [Id. at 4, Pg ID 44]. Additionally, Allen stated that Koehler was uncooperative and that the statements Koehler made “were often not rational or grounded in reality.” [Id.]. Finally, Allen stated that other individuals who had interacted with Koehler had concerns about his mental competency, including Koehler's parents and two attorneys representing Koehler in pending criminal and probation violation matters in state court. [Id.].

         As a result, on October 16, 2018, the Court ordered that Koehler be committed to the custody of the United States Attorney General so that a mental health evaluation could be conducted. [DE 24]. Koehler was evaluated by Dr. Alicia Gilbert, a forensic psychologist, who stated,

[I]t is the professional opinion of this writer that Mr. Koehler's present ability to understand the nature and consequences of the court proceedings brought against him, as well as his ability to properly assist counsel in a defense are substantially impaired by a mental disease or defect. Mr. Koehler appears to be suffering from symptoms associated with a Bipolar Disorder with delusional, distorted, and grandiose thinking. He is overly confident about his abilities to fight his legal case and his narcissistic traits appear to interfere with his ability to listen to reason or the advice of others.

[DE 32 at 17, Pg ID 91]. Dr. Gilbert went on to say that,

Fortunately, individuals with Bipolar Disorder respond well to medication treatment, . . . However, it is unclear if he will comply voluntarily to medication treatment as he has no insight and is currently unable to recognize that he has a problem.

[Id.].

         Subsequently, the Court scheduled a competency hearing and appointed attorney Patrick Nash as counsel for Koehler since Mr. Allen had moved to withdraw as counsel. [DE 38]. The competency hearing has been rescheduled twice to ensure that Mr. Nash was adequately prepared to represent Mr. Koehler in these proceedings. [DE 41; DE 50]. Additionally, Koehler sent several letters directly to the Court that are filed in the record.

         At the competency hearing, Dr. Alicia Gilbert, the forensic psychologist who evaluated Mr. Koehler, testified and stated that her professional opinion continued to be that Koehler demonstrated symptoms of Bipolar Disorder and the he is currently incompetent to stand trial. Dr. Gilbert was also subject to cross-examination by defense counsel. Finally, the Defendant introduced three exhibits for the Court's consideration, including two mental health evaluations performed in May and June 2018.

         After considering all the record evidence, the Court made a finding that a preponderance of the evidence supported a finding that Mr. Koehler is currently suffering from a mental disease or defect that renders him incompetent to stand trial. This memorandum opinion and order memorializes the Court's finding during the hearing and provides more specific instructions for Koehler's confinement.

         II. Legal Standards

         Due process categorically prohibits subjecting a criminal defendant who is mentally incompetent to proceed to trial or to enter a guilty plea. See, e.g., Godinez v. Moran, 509 U.S. 389 (1993); Drope v. Missouri, 420 U.S. 162 (1975). A criminal defendant is mentally incompetent to stand trial if he is presently “suffering from a mental disease or defect rendering him mentally incompetent to the extent that he is unable to understand the nature and consequences of the proceedings against him or to assist properly in his defense.” 18 U.S.C. § 4241(a). Still, courts must take certain steps to determine the competency of a criminal ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.