United States v. Kyulle Jay Strong

The district court found Defendant-Appellant Kyulle Jay Strong incompetent to stand trial and committed him to the custody of the Attorney General for treatment and restoration pursuant to 18 U.S.C. § 4241 (d). Strong appeals the district court’s commitment order, arguing that § 4241(d) is unconstitutional because it requires mandatory confinement without giv: ing the district court an opportunity to assess a defendant’s individualized circumstances. We conclude that § 4241(d) comports with the Due Process Clause of the Constitution and affirm the commitment order of the district court.

I. BACKGROUND

On November 9, 2005, a grand jury in the District of Arizona indicted Strong and two co-defendants for assault "with a dangerous weapon in violation of 18 U.S.C. §§ 1153 and 113(a)(3), and assault resulting in serious bodily injury in violation of 18 U.S.C. §§ 1153 and 113(a)(6). Before trial, Strong filed a motion with the district court for determination of his mental competency. After reviewing psychiatric reports submitted by Strong and the government, the district court concluded that Strong was incompetent to stand trial and committed him to the custody of the Attorney General…