USA v. Stone

2018 DNH 112
CourtDistrict Court, D. New Hampshire
DecidedMay 29, 2018
Docket15-cr-161-LM
StatusPublished

This text of 2018 DNH 112 (USA v. Stone) 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. Stone, 2018 DNH 112 (D.N.H. 2018).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal No. 15-cr-161-LM Opinion No. 2018 DNH 112 John J. Stone

O R D E R

On May 15, 2018, the court held a competency hearing with

respect to defendant John J. Stone. At the end of the hearing,

the court concluded that Stone is incompetent and not

restorable. This order explains the court’s decision.

BACKGROUND

In September 2015, Stone was indicted on charges related to

allegations that he fraudulently obtained Supplemental Security

Income benefits. The charges consist of two counts of

concealing events affecting the right to payment of social

security benefits; one count of making a false statement; and

three counts of wire fraud. In December 2016, defense counsel

moved for a competency hearing pursuant to 18 U.S.C. § 4241,

which the government did not oppose. The court granted the

motion.

The court’s task at the initial phase was to determine

whether Stone was presently suffering from a “mental disease or defect rendering him mentally incompetent to the extent that he

is unable understand the nature and consequences of the

proceedings against him or to assist properly in his defense.”

18 U.S.C. § 4241(d); see also United States v. Wiggin, 429 F.3d

31, 36-37 (1st Cir. 2005). The court ultimately held two

hearings, on January 24 and March 6, 2017. At the January

hearing, the court heard testimony from government-retained

expert Dr. Albert M. Drukteinis, a forensic psychiatrist. He

opined that, primarily due to a neurocognitive disorder, Stone

was unable to properly assist in his defense or rationally

participate in the proceedings. Dr. Drukteinis also opined that

Stone’s competency was not restorable.

At the March hearing, the court concluded on the record

that Stone was incompetent, based on Dr. Drukteinis’s thorough

and credible opinion. Importantly, the government did not

dispute Dr. Drukteinis’s conclusions.

Having come to that determination, the court was compelled

by statute to commit Stone to the custody of the Attorney

General for hospitalization and treatment. 18 U.S.C. § 4241(d).

This is so despite the undisputed determination that Stone’s

competence was not restorable. See, e.g., United States v.

Magassouba, 544 F.3d 387, 404-05 (2d Cir. 2008). The

justification for such mandatory hospitalization is that it

2 enables “medical professionals to accurately determine whether a

criminal defendant is restorable to mental competency,” United

States v. Strong, 489 F.3d 1055, 1062 (9th Cir. 2007), and gives

the Attorney General an opportunity to explore possible medical

options. United States v. Ferro, 321 F.3d 756, 762 (8th Cir.

2003); United States v. Filippi, 211 F.3d 649, 651 (1st Cir.

2000).

To that end, the statute required that Stone be

hospitalized “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.” 18 U.S.C. § 4241(d)(1). Given Dr. Drukteinis’s

uncontroverted opinion that Stone was not restorable, the court

recommended that “the evaluation of the defendant be conducted

as expeditiously as possible.” Doc. no. 37 at 4. This was in

keeping with the case law, which emphasizes that, while “the

statute is categorical in determining who shall be incarcerated,

. . . it is much more flexible and case-oriented in determining

the length of incarceration.” Filippi, 211 F.3d at 652.

Nevertheless, Stone was held for about four months, in what

was described as a “semi-locked” mental health unit at the

Federal Medical Center in Devens, Massachusetts. As was later

3 revealed during the testimony of Dr. Shawn Channell, a forensic

psychologist at FMC-Devens, Stone’s treatment over those four

months amounted to (1) an increase in his antidepressant

medication, and (2) exposure to the criminal-justice process

through meetings with mental-health professionals and a

“competency restoration group.” In the competency restoration

group, which consisted of nine classes over the course of two

months, Stone learned about various aspects of the criminal-

justice system.

In late September 2017, Stone was released, and the Warden

of FMC-Devens filed a certificate attesting that his staff had

found Stone to be competent. See 18 U.S.C. § 4241(e) (stating

that the director of the hospitalizing facility shall file a

certificate once it is determined that the defendant has

sufficiently recovered to be deemed competent).

The present issue, and the subject of the May 15 hearing,

is to determine whether Stone has been restored or is otherwise

restorable. Specifically, § 4241(d) states as follows: “If, at

the end of the time period specified, it is determined that the

defendant’s mental condition has not so improved as to permit

the proceedings to go forward, the defendant is subject to the

4 provisions of sections 4246 and 4248.”1 Id. § 4241(d). At the

hearing, the government presented the testimony of Dr. Channell

and Dr. Drukteinis.

Dr. Channell opined that Stone was restored to competence

over the course of his hospitalization. Dr. Channell believed

that Stone’s deficits were grounded more in his anxiety and

depression than a neurocognitive disorder. For that reason, Dr.

Channell claimed that by increasing the dosage of his

antidepressant medication and exposing him to the criminal-

justice process, Stone’s deficits—his perseveration, inability

to focus, etc.—diminished to a degree that allowed him to

meaningfully participate in his defense. Dr. Channell noted an

important caveat to his opinion, however: even with diminished

symptoms, Stone would need significant accommodations in the

trial or plea process to assist in his own defense. At trial,

accommodations would include slowing the pace of proceedings and

providing frequent breaks, while for a plea Stone would need

questions repeated and would need information simplified. Dr.

Channell further opined that if the court were to find that

1 Similarly, after a facility director files a certificate of competence, the court must determine whether “the defendant has recovered to such an extent that he is able to understand the nature and consequences of the proceedings against him and to assist properly in his defense.” 18 U.S.C.

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Related

United States v. Magassouba
544 F.3d 387 (Second Circuit, 2008)
United States v. Ecker
78 F.3d 726 (First Circuit, 1996)
United States v. Filippi
211 F.3d 649 (First Circuit, 2000)
United States v. Wiggin
429 F.3d 31 (First Circuit, 2005)
United States v. Louie A. Ferro, Sr.
321 F.3d 756 (Eighth Circuit, 2003)
United States v. Kyulle Jay Strong
489 F.3d 1055 (Ninth Circuit, 2007)

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2018 DNH 112, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usa-v-stone-nhd-2018.