USA v. Giovanella

CourtDistrict Court, D. New Hampshire
DecidedApril 20, 1993
DocketCR-92-87-B
StatusPublished

This text of USA v. Giovanella (USA v. Giovanella) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USA v. Giovanella, (D.N.H. 1993).

Opinion

USA v . Giovanella CR-92-87-B 04/20/93 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal N o . 92-087-01-B

Albert L . Giovanella, J r .

O R D E R

Defendant Albert L . Giovanella, J r . has moved to postpone

indefinitely his trial on an eleven-count indictment because he

allegedly is too ill to stand trial. For the reasons that

follow, I deny his request.

I. Procedural History

The defendant was indicted along with his son, Albert L .

Giovanella, I I I , and Louis J. Berger in October 1992. 1 The

indictment charges the defendant with wire fraud, 18 U.S.C. § 1343, conspiracy, 18 U.S.C. § 3 7 1 , bank fraud, 18 U.S.C. § 1344,

various counts of laundering monetary instruments, 18 U.S.C. §

1956, engaging in a monetary transaction involving criminally

derived proceeds, 18 U.S.C. § 1957, and the use of false

documents to avoid a student loan debt, 18 U.S.C. § 1001.

1 Defendant Berger plead guilty prior to trial and the charges against the defendant were severed from those against his son. The wire fraud, bank fraud, and conspiracy charges result

from the purchase of a home by the defendant's son. The

Government alleges that the defendant masterminded a criminal

conspiracy to enable his son to purchase the home by fraudulently

obtaining a substantial mortgage loan. The money laundering

charges concern funds that the defendant allegedly obtained from

third parties to cover certain additional costs associated with

the purchase of the home. The false document charge concerns

documents that the defendant allegedly submitted to a government

agency to avoid his son's student loan debts.

On February 1 9 , 1993, I held an evidentiary hearing on

defendant's Motion for Indefinite Postponement of Trial (document

no. 3 7 ) . Following the hearing, I reviewed the videotape

depositions of several witnesses who could not be present at the

hearing. I also reviewed the exhibits produced at the hearing,

as well as affidavits and memoranda submitted after the hearing

at my request.

II. Discussion

A. The Legal Standard

The First Circuit Court of Appeals has articulated a clear

legal standard which must be used in ruling on a claim that a

defendant is too ill to stand trial. This standard requires the

2 exercise of discretion in weighing the risk of harm to the

defendant against the public's interest in a trial. United

States v . Zannino, 895 F.2d 1 , 13-14 (1st Cir. 1990), cert.

denied, 494 U.S. 1082 (1990). In considering the defendant's

interest, the court has held that "the impending trial must pose

a substantial danger to a defendant's life or health" in order to

justify a continuance. Id. at 14 (quoting United States v .

Brown, 821 F.2d 986, 988 (4th Cir. 1987)). In assessing a claim

of medical dangerousness, the [district] court must carefully investigate the situation, assemble the pertinent data, and then consider not only the medical evidence but also the defendant's activities (in the courtroom and out of i t ) , the steps defendant is taking (or neglecting to take) to improve his health, and the measures which can feasibly be implemented to reduce medical risks.

Id. In weighing the public's interest, the district court should

consider the likelihood that the defendant's medical condition will improve over time so that a trial can occur at a later date,

the nature and severity of the charges, and the Government's

interest in trying the defendant. Id.

B. The Defendant's Medical Condition

The defendant suffers from post-polio syndrome. This

condition develops twenty-five to thirty-five years after the

3 onset of polio and manifests itself by weakness in the muscles in areas previously affected by the polio. It is a serious medical condition which only worsens with time and can lead to death. In the defendant's case, the post-polio syndrome has significantly affected his ability to breathe without support from a

ventilator. He also has difficulty swallowing, and the disease has affected his arms and legs.

Approximately four years ago, the defendant underwent a tracheotomy so that he could use a ventilator to help him breathe. The defendant is currently required to use a ventilator for as much as seventeen hours per day and can breathe without the ventilator for no more than two to three hours at a time. Accordingly, he would be required to use a ventilator during the trial.

The defendant uses a portable ventilator which fits on the top of a nightstand and could easily be used by the defendant in court. The defendant has chosen not to use a device which would allow him to speak while he is using the ventilator. However, the defendant could remove himself from the ventilator for several hours at a time to testify if he wished to do s o . He would be able to communicate with counsel and the court in writing while he is using the ventilator.

4 The defendant also suffers from a significant psychological condition. He has received electroconvulsive treatment on several occasions in the past and has attempted suicide more than once. He is currently taking several psychiatric medications. He has suffered in the past from bipolar disorder, which is in remission at the present time. He currently suffers from adjustment disorder with anxiety. His difficulty in dealing with anxiety is exacerbated by stress. One psychologist who examined him stated that he thought it was unlikely that the defendant could participate in a trial because of the effect that the stress of trial would have on his physical condition.2

I received testimony from three pulmonologists who examined the defendant and are familiar with his medical condition. None of these experts testified that it would cause a substantial risk to the defendant's health if he were required to stand trial under proper circumstances. D r . Bartolome Celli, a pulmonologist

2 Dr. Ronald Ebert wrote a letter to the defendant's counsel in which he offered this opinion. His opinion appears to be based primarily on a concern that the stress of trial would cause the defendant to hyperventilate and thus render his ventilator ineffective. D r . Ebert reported that a respiratory therapist told him that such an occurrence could have fatal consequences. I discount this opinion because the pulmonologists who testified on this subject agreed that there was no significant likelihood that the defendant would die or suffer serious injury from hyperventilation.

5 with extensive experience in treating post-polio syndrome, opined that it would not threaten or shorten the defendant's life to subject him to the stress of a trial. D r .

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