alienist

Monte Durham was convicted of housebreaking by the District Court of the District of Columbia sitting without a jury. The prosecution proceeded on a charge arising from an incident on July 13, 1951, in which Durham was found in a house. Durham's history included discharge from the Navy in 1945 at age seventeen following a psychiatric examination revealing a profound personality disorder rendering him unfit for service. In 1947 he pleaded guilty to violating the National Motor Theft Act and was placed on probation for one to three years. In January 1948, as a result of a conviction in the District of Columbia Municipal Court for passing bad checks, the District Court revoked his probation and he commenced service of his Motor Theft sentence. His conduct within the first few days in jail led to a lunacy inquiry in the Municipal Court where a jury found him to be of unsound mind. Upon commitment to St. Elizabeths he was diagnosed as suffering from 'psychosis with psychopathic personality.' He experienced multiple discharges and readmissions to St. Elizabeths between 1949 and 1951, including a conditional release in June 1950 that he violated, and a further lunacy finding in 1951. Following the July 1951 housebreaking, Durham was indicted in October 1951 and adjudged of unsound mind based on psychiatrists' affidavits diagnosing psychosis with psychopathic personality. He underwent subshock insulin therapy during a six-month commitment ending in February 1953, after which Dr. Silk certified him mentally competent to stand trial and able to assist counsel. At the ensuing trial, the prosecutor expressed a plan to allow Durham to raise an insanity defense on this charge. The court accepted waivers of jury trial and additional competency proceedings despite Durham's expressed desire for further hospitalization. Testimony included that of Durham's mother regarding his post-May 1951 behavior and a psychiatrist who examined him in September 1951 and opined on his mental condition around the time of the offense. The trial court found the defense of insanity not established under the prevailing standards. The appeal reached the United States Court of Appeals for the District of Columbia Circuit.

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Charles Sell, a former licensed dentist, exhibited unusual behavior beginning in the late 1980s and was hospitalized multiple times for mental illness. In 1997 the Government charged him with submitting false Medicaid claims and making false statements to a law enforcement officer; a superseding indictment later added fifty-six counts of mail fraud, six counts of Medicaid fraud, and one count of money laundering. In early 1998 Sell's bail was revoked after a magistrate judge observed him screaming, shouting, and spitting in court, and a psychiatrist reported his condition had worsened. A new indictment in April 1998 charged Sell with attempting to murder an FBI agent and a potential witness. In May 1998 a magistrate judge found Sell incompetent to stand trial and ordered him hospitalized at the United States Medical Center for Federal Prisoners in Springfield, Missouri, for up to four months to determine whether he would attain capacity to proceed. While there, Sell refused staff recommendations to take antipsychotic medication. Medical Center authorities sought and obtained administrative approval to administer the drugs involuntarily after a hearing that considered Sell's history, current delusions, staff opinions, and an outside expert's view. Sell challenged the administrative decision in court. A magistrate judge held an evidentiary hearing that included testimony about a July 1999 incident in which Sell approached a nurse inappropriately and indicated the conduct would continue; the magistrate authorized involuntary medication, finding Sell dangerous to himself and others, that medication was the only way to render him less dangerous and competent, and that side effects could be ameliorated. The District Court reviewed the record, held the dangerousness finding clearly erroneous after Sell was returned to an open ward, but affirmed the medication order on the ground that drugs represented the only viable hope of restoring competence to allow adjudication of the charges. The Court of Appeals for the Eighth Circuit affirmed, agreeing that Sell was not dangerous at the Medical Center but concluding that the Government had an essential interest in bringing him to trial on the fraud charges, that medication was medically appropriate, and that the evidence showed a reasonable probability Sell could fairly participate in his defense. Sell petitioned for certiorari, which the Supreme Court granted.

In 1984, Teofilo Medina, Jr., stole a gun from a pawnshop in Santa Ana, California. Over the following weeks, he committed multiple armed robberies of gas stations, a drive-in dairy, and a market, during which he murdered three employees and shot at two passersby. He was apprehended less than a month after the crime spree began and charged with three counts of first-degree murder and other offenses. Before trial, Medina's counsel moved for a competency hearing under California Penal Code section 1368, expressing uncertainty about Medina's ability to participate in the proceedings. The trial court granted the motion, and a six-day hearing was held before a jury. During the hearing, the jury heard conflicting testimony from multiple psychiatrists and psychologists regarding Medina's mental condition, including diagnoses of paranoid schizophrenia and depression, as well as observations of his verbal and physical outbursts, such as overturning the counsel table. The trial court instructed the jury that Medina was presumed mentally competent and bore the burden of proving his incompetence by a preponderance of the evidence under California Penal Code section 1369(f). The jury found Medina competent to stand trial. At the conclusion of the guilt phase, petitioner was found guilty of all three counts of first-degree murder and lesser offenses. A sanity hearing was held, and the jury found that petitioner was sane at the time of the offenses. At the penalty phase, the jury found that the murders were premeditated and deliberate and returned a verdict of death. On direct appeal, the California Supreme Court affirmed the conviction and sentence. Medina later filed a habeas corpus petition in the California Supreme Court, which appointed a referee for an evidentiary hearing; the referee found Medina had been competent, and the court adopted those findings. Medina then sought federal habeas relief in the United States District Court for the Central District of California, which was denied, and the Ninth Circuit affirmed. The Supreme Court granted certiorari to address the constitutionality of the state statute allocating the burden of proof on competency to the defendant.