United States v. Tarner

CourtDistrict Court, District of Columbia
DecidedNovember 29, 2023
DocketCriminal No. 2020-0183
StatusPublished

This text of United States v. Tarner (United States v. Tarner) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Tarner, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. Case No. 1:20-cr-183-RCL

CODY MICHAEL TARNER,

Defendant.

MEMORANDUM AND ORDER

The defendant, Cody Michael Tarner, seeks release from federal custody and dismissal of

his indictment for alleged violations of the procedure and timeline established by the Insanity

Defense Reform Act (IDRA). Because Mr. Tarner is no longer committed for competency

evaluation or restoration, his motion is moot. Therefore, the Court will DENY Mr. Tarner’s

motion to dismiss. For the reasons discussed below, the Court will also DENY Mr. Tarner’s

motion to seal his motion to dismiss, and will DENY the Government’s motion to file a sur-reply.

In addition, now that Mr. Tarner has given notice of his intention to present an insanity

defense, the parties agree that the Court should order a psychiatric or psychological examination

and report of Mr. Tarner. However, they disagree on whether the Court must order Mr. Tarner

committed to the custody of the Attorney General of the United States for that evaluation. The

Court concludes that committing Mr. Tarner to the custody of the Attorney General will likely

result in lengthy delay, and therefore orders that Mr. Tarner be evaluated where he is currently

housed, the D.C. Correctional Treatment Facility.

1 I. BACKGROUND

A. Factual and Procedural Background

The Government alleges that on July 15, 2020, Mr. Tarner approached three government

vehicles parked at the United States Supreme Court, doused them with liquid, and then lit one of

them ablaze. See Compl., ECF No. 1, at 2. However, the fire spread to Mr. Tarner himself,

resulting in burns to about 40% of his body. See id. For these events, a grand jury indicted Mr.

Tarner on one count of Arson, in violation of 18 U.S.C. § 844(i), and one count of Destruction of

Government Property, in violation of 18 U.S.C. § 1361. See Indictment, ECF No. 6. The

magistrate judge ordered Mr. Tarner detained pending trial. See ECF No. 5.

1. Mr. Tarner’s Commitment for Competency Evaluation

At a status conference on February 12, 2021, the Court granted defense counsel’s oral

motion for a competency examination. See ECF No 9, at 1. The Court ordered that Mr. Tarner

“be committed to the custody of the Attorney General of the United States pursuant to 18 U.S.C.

§ 4247(b) for a period not to exceed thirty days for placement in a suitable facility for a competency

examination.” Id. The Court also required the Government to update the Court every ten days on

Mr. Tarner’s placement and his transportation to this facility. Id. at 2.

On April 15, 2021, the Government reported that Mr. Tarner had been transported to the

Butner Federal Correctional Complex in North Carolina. See ECF No. 14. In a letter filed under

seal on April 22, 2021 (but dated April 15, 2021) the warden informed the Court that per C.D.C.

and B.O.P. guidance, when Mr. Tarner arrived he was put in quarantine that would “last

approximately 21 days.” See ECF No. 15. The warden requested that the 30-day evaluation period

begin on the date of Mr. Tarner’s release from quarantine and be extended 15 days. See id. At an

April 22 status conference, the Court granted the request for an extension of time.

2 2. Mr. Tarner’s Commitment for Restoration

Another letter from the warden was filed under seal on July 21, 2021 (but dated June 9,

2021), along with Mr. Tarner’s competency evaluation. See ECF No. 17. The evaluator found

Mr. Tarner not competent and recommended that he be committed to the custody of the Attorney

General for restoration to competency. See id. at 13. Mr. Tarner was then transferred to the D.C.

Jail. Def. Mot. for Immediate Transfer to Butner FMC, ECF No. 18, at 2.

On August 6, the Court held a status conference. On August 9, the Court issued an order

in which it, “[a]fter holding a hearing, and with the consent of the Government and defense

counsel,” adopted the medical opinion in the competency evaluation report and found Mr. Tarner

not competent. See ECF No. 18, at 1. Pursuant to 18 U.S.C. § 4241(d), the Court ordered Mr.

Tarner committed to the custody of the Attorney General, to be “hospitalize[d] 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.’” See id. (quoting 18 U.S.C. § 4241(d)(1)).

From the date of the Court’s Order until November 17, 2021, the Government filed nine status

reports on Mr. Tarner’s pending transportation and evaluation.

On November 18, 2021, Mr. Tarner objected to the delay by filing a “Motion for Immediate

Transfer to Butner FMC.” See ECF No. 18. Until the present motion, this was the only time Mr.

Tarner objected to the timing of his transport, evaluation, or treatment. Finally, on January 14,

2022 the Government reported that Mr. Tarner had been transferred to Butner the previous day.

See ECF No. 31. In May 2022, the warden informed the Court that Mr. Tarner’s restoration

evaluation was complete. See ECF No. 32-1. Although the attached competency report assessed

Mr. Tarner to be not competent, the evaluators reported “some improvement in [his] symptoms,”

3 stated that he would likely be restored to competency in the future, and asked for an additional 120

days to restore Mr. Tarner to competency. See ECF No. 32-1, at 14. The letter and report were

filed on the Court’s docket on July 8 and on July 29 the Court issued an order granting a 120-day

treatment period, see July 29 2022 Order, ECF No. 33. It did so pursuant to 18 U.S.C.

§ 4241(d)(2)(A). That provision authorizes the Attorney General to hospitalize a mentally

incompetent defendant for treatment in a suitable facility for an additional period of time until

defendant’s “medical condition is so improved that trial may proceed” if a court finds a “substantial

probability that within such additional period of time [the defendant] will attain the capacity to

permit the proceedings to go forward.” 18 U.S.C. § 4241(d)(2)(A).

On November 10, 2022, the warden informed the Court that Mr. Tarner’s competency had

been restored. See ECF No. 34. On December 5, the parties submitted a joint status report

requesting that Mr. Tarner be returned to the District of Columbia. See ECF No. 35. On January

11 the Court held a status conference and on January 23 it issued an order finding Mr. Tarner

competent. See ECF No. 37. Currently, Mr. Tarner is housed at the D.C. Correctional Treatment

Facility. Def. Proposed Order, ECF No. 64, at 2.

B. The Present Dispute

On August 22, 2023 Mr. Tarner gave notice of his intention to present an insanity defense

at trial. See ECF No. 47. On October 2, the Court held a status conference in which it vacated the

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