United States v. Randall B. Husar

859 F.2d 1494, 273 U.S. App. D.C. 347, 1988 U.S. App. LEXIS 14692, 1988 WL 114404
CourtCourt of Appeals for the D.C. Circuit
DecidedNovember 1, 1988
Docket87-3076, 88-3020
StatusPublished
Cited by4 cases

This text of 859 F.2d 1494 (United States v. Randall B. Husar) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. 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. Randall B. Husar, 859 F.2d 1494, 273 U.S. App. D.C. 347, 1988 U.S. App. LEXIS 14692, 1988 WL 114404 (D.C. Cir. 1988).

Opinion

Opinion PER CURIAM.

PER CURIAM:

Randall B. Húsar appeals from the district court’s final judgment and order committing him to the custody of the Attorney General after an acquittal by reason of insanity, and its subsequent order denying his Motion for Release from Federal Custody. For the reasons stated hereafter, we affirm the district court’s dispositions.

Background

An indictment filed November 6, 1986 charged Húsar, under 18 U.S.C. § 1361, with destruction of government property in excess of $100. The offense occurred on October 10, 1986 in the National Archives when Húsar smashed with a hammer a glass case that housed the original Constitution and Bill of Rights.

Initially found incompetent to stand trial, Húsar was arraigned on the indictment on March 5, 1987 after he regained competency. On June 3, 1987, he was found not guilty only by reason of insanity.

Pursuant to 18 U.S.C. § 4243(a), Húsar was immediately committed to St. Eliza-beths Hospital for an evaluation of his current mental state. At a hearing held August 24, 1987, the district court received testimony from a hospital psychiatrist and a psychologist. Each concluded that Hu-sar’s mental condition made him a danger to society if released.

Finding that Husar’s offense had caused “serious damage to property,” the district court held that Húsar had failed to prove by clear and convincing evidence that his release would not create a substantial danger to the property and person of others *1496 due to his mental state. See 18 U.S.C. § 4243(d).

Húsar was then committed to the custody of the Attorney General. Under 18 U.S.C. § 4247(i)(A), the Attorney General is charged with the responsibility to “contract ... for the confinement, hospitalization, care, or treatment of ... a person committed to his custody” pursuant to § 4243(e). Section 4243(e) in turn provides:

The Attorney General shall release the person to the appropriate official of the State in which the person is domiciled or was tried if such State will assume responsibility for his custody, care, and treatment.

18 U.S.C. § 4243(e) (Supp. Ill 1985).

Accordingly, on December 9, 1987 the Attorney General, through the Federal Bureau of Prisons, wrote to Colorado mental health officials advising them that he was prepared to place Húsar for care and treatment with the State on the following terms:

Under 18 U.S.C. § 4243(e), the Attorney General is to release Mr. Húsar to the custody of the State of Colorado, if the state will assume responsibility for his custody, care and treatment. In addition, 18 U.S.C. § 4243(f) provides that before the person is released or conditionally released from your custody, a certificate is to be filed with the committing court (here, the U.S. District Court for the District of Columbia) to the effect that the person no longer presents a substantial risk of injury to another, or serious risk to property. The possibility exists that a hearing may then be scheduled concerning the release. However, that possibility may be minimized by providing a factual basis for the release in the certificate. Finally, the statute also provides (18 U.S.C. § 4247(e)(l)(8)) [sic] that annual reports concerning the mental condition of the person and containing recommendations concerning the need for his continued hospitalization be filed, with the committing court....
I understand these conditions governing Mr. Husar’s commitment and release are acceptable to you.

Letter from Clair Cripe, General Counsel, Bureau of Prisons to Jack Bartteson, Deputy Director, Division of Mental Health (Dec. 9, 1987) [hereinafter Federal letter of transfer] (emphasis supplied).

The Colorado officials accepted these terms when they received Húsar into their care for treatment. The terms, we note, comport with the statute. 1

In the interim, Húsar had filed a Motion for Release from Federal Custody in November 1987. The government’s response informed the district court of the final arrangements then underway to release Hú-sar to Colorado, and argued that as a result, Husar’s motion was moot.

Citing the letter from the Bureau of Prisons to the Colorado officials, Húsar objected to the Attorney General’s imposition of any federal conditions upon his stay in Colorado. Specifically, he objected to the continuing reporting requirements imposed upon the state, as well as the Attorney General’s reservation of the federal government’s right to conduct a hearing in federal district court pursuant to federal standards for discharge as prescribed in 18 U.S.C. § 4243(f). 2

*1497 Húsar further argued that such proposed retention of federal control prevented his motion from becoming moot, since the federal reporting and discharge standards were more stringent than those applicable under Colorado’s civil commitment statutes. 3 He also averred that he “is not asserting that he has recovered and should therefore be discharged from [the] hospital.” 4

In an Order filed January 29, 1988, the district court observed that Húsar had in fact been surrendered by the Attorney General and sent to Colorado, as previously indicated. The court therefore dismissed Husar’s Motion for Release from Federal Custody as moot.

On appeal Húsar urges:

(1) He is entitled to complete release from federal custody; and

(2) His offense did not involve “serious damage to property”; consequently, he is not required to prove his mental health by clear and convincing evidence rather than by a preponderance of the evidence.

Discussion

Under 18 U.S.C. §§ 4243, 4247, the Attorney General clearly had the authority to stipulate the terms and conditions under which Húsar would be placed in Colorado state custody for care and treatment— terms that the state officials agreed to assume.

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Related

United States v. Weston
134 F. Supp. 2d 115 (District of Columbia, 2001)
United States v. Bridget M. Denny-Shaffer
2 F.3d 999 (Tenth Circuit, 1993)
United States v. Randall B. Husar
866 F.2d 1533 (D.C. Circuit, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
859 F.2d 1494, 273 U.S. App. D.C. 347, 1988 U.S. App. LEXIS 14692, 1988 WL 114404, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-randall-b-husar-cadc-1988.