United States v. Craig Donnelly

41 F.4th 1102
CourtCourt of Appeals for the Ninth Circuit
DecidedJuly 22, 2022
Docket22-30081
StatusPublished
Cited by8 cases

This text of 41 F.4th 1102 (United States v. Craig Donnelly) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Craig Donnelly, 41 F.4th 1102 (9th Cir. 2022).

Opinion

FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 22 2022 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 22-30081

Plaintiff-Appellee, D.C. Nos. 3:21-cr-00232-SI-1 3:21-cr-00232-SI v. OPINION CRAIG THOMAS DONNELLY,

Defendant-Appellant.

Appeal from the United States District Court for the District of Oregon Michael H. Simon, District Judge, Presiding

Argued and Submitted July 5, 2022 Portland, Oregon

Before: Paul J. Watford, Ryan D. Nelson, and Kenneth K. Lee, Circuit Judges.

Per Curiam Opinion; Concurrence by Judge Watford

PER CURIAM:

Craig Donnelly is charged with three counts of stalking, cyberstalking, and

interstate violation of a protective order. The district court ordered him detained

without bail under 18 U.S.C. § 3142 as both a danger to the community and a flight

risk. He has been held since his initial appearance in August 2021 at the federal

detention center in Sheridan, Oregon. Page 2 of 12

On November 18, 2021, after ordering a psychological evaluation and

conducting a hearing to evaluate Donnelly’s competency to stand trial, the district

court found that Donnelly “is suffering from a mental disease or defect rendering

him mentally incompetent to the extent that he is presently unable to assist

properly in his defense of this criminal matter.” As required under the Insanity

Defense Reform Act (IDRA), the district court committed Donnelly to the custody

of the Attorney General. See 18 U.S.C. § 4241.

The IDRA directs the Attorney General to “hospitalize the defendant for

treatment in a suitable facility . . . for such a reasonable period of time, not to

exceed four months, as is necessary to determine whether there is a substantial

probability that in the foreseeable future he will attain the capacity to permit the

proceedings to go forward.” Id. § 4241(d)(1). The Attorney General has delegated

responsibility for complying with this requirement to the Bureau of Prisons (BOP).

The BOP, however, is currently experiencing a significant backlog in placing

defendants in suitable facilities for treatment, as § 4241(d) requires. The lack of

available bed space has led to long delays between the time a district court finds a

defendant not competent to stand trial and the defendant’s hospitalization for

treatment and evaluation.

Four months after the district court issued its order remanding him to the

Attorney General’s custody, Donnelly remained detained in Oregon awaiting Page 3 of 12

hospitalization. He was informed that he would likely have to wait another four

months—until July 2022—before a bed would become available.

In March 2022, Donnelly filed the motion giving rise to this appeal, which

asked the district court to dismiss the indictment. Donnelly argued that the four-

month-plus delay in placing him in a suitable hospital facility violated his rights

under 18 U.S.C. § 4241(d) and the Fifth Amendment’s Due Process Clause. As

the basis for his statutory argument, Donnelly contended that the four-month time

limit imposed by § 4241(d)(1) begins to run when the district court orders a

defendant committed to the custody of the Attorney General for placement in a

suitable hospital facility. Under that reading, Donnelly’s rights have been violated

because he has already been in the Attorney General’s custody for more than four

months, and he still has not been hospitalized for treatment.

On May 11, 2022, the district court denied Donnelly’s motion to dismiss the

indictment. It rejected Donnelly’s statutory argument on the ground that

§ 4241(d)’s four-month time limit begins to run only upon the defendant’s

hospitalization, not upon his commitment to the Attorney General’s custody. The

district court reasoned that the four-month time limit had not yet begun to run,

much less been violated, because Donnelly had not yet been hospitalized. The

court rejected Donnelly’s due process argument on the ground that he had not

shown the kind of “grossly shocking and outrageous” government misconduct Page 4 of 12

necessary to warrant dismissal of the indictment. United States v. Kearns, 5 F.3d

1251, 1253 (9th Cir. 1993).

Donnelly filed an interlocutory appeal challenging the denial of his motion

to dismiss the indictment. We have jurisdiction to hear his appeal under the

collateral order doctrine, as the district court’s order conclusively resolves issues

separate from the underlying merits of the criminal charges against Donnelly (i.e.,

Donnelly’s continued detention) and would be effectively unreviewable on appeal

from a final judgment. See Sell v. United States, 539 U.S. 166, 176–77 (2003).

We agree with the district court’s decision to deny Donnelly’s motion,

although our reasoning differs in certain respects and ultimately requires that we

vacate the order below. The IDRA establishes a three-step process when a criminal

defendant’s competency to stand trial is questioned. First, it provides that, “[a]t any

time after the commencement of a prosecution for an offense and prior to the

sentencing of the defendant,” either party may move for a hearing to determine the

defendant’s competency. 18 U.S.C. § 4241(a). The court holds a hearing on the

motion and makes a competency finding. Id. § 4241(c), (d). If the court finds that

the defendant is incompetent to stand trial, “the court shall commit the defendant to

the custody of the Attorney General.” Id. § 4241(d). Second, “[t]he Attorney

General shall hospitalize the defendant for treatment in a suitable facility . . . for such

a reasonable period of time, not to exceed four months, as is necessary to determine Page 5 of 12

whether there is a substantial probability” that the defendant will be restored to

competency in the foreseeable future. Id. § 4241(d)(1). Finally, after the initial

evaluation, continued hospitalization is permitted “for an additional reasonable

period of time” until the defendant’s mental condition has improved or the pending

charges are “disposed of according to law.” Id. § 4241(d)(2).

The IDRA thus imposes two mandatory duties following an incompetency

finding. First, the district court “shall commit the defendant to the custody of the

Attorney General.” Id. § 4241(d). Second, “[t]he Attorney General shall hospitalize

the defendant for treatment in a suitable facility . . . for such a reasonable period of

time, not to exceed four months.” Id. § 4241(d)(1). We think the text of the statute

makes clear that the four-month time limit applies only to the period of

hospitalization, and thus begins to run when the defendant has been hospitalized.

Even so, that does not establish whether the statute permits a delay between

commitment and hospitalization. If hospitalization must occur immediately upon

commitment, the four-month clock starts when the defendant is committed. But if

the statute allows some amount of time between commitment and hospitalization,

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Cite This Page — Counsel Stack

Bluebook (online)
41 F.4th 1102, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-craig-donnelly-ca9-2022.