United States v. Andrew Ryan
Submitted: September 20, 2022, Filed: October 28, 2022 (2022)
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Rule of Law:
The statutory time limitations for competency evaluations under 18 U.S.C. § 4241(d) are non-jurisdictional, claims-processing rules. Therefore, a defendant waives the right to challenge an alleged violation of these time limits if they fail to raise the issue in the court that ordered the commitment, and they cannot later use the alleged violation to dismiss a subsequent civil commitment proceeding under § 4246.
Facts:
- In June 2018, Andrew Ryan was charged with two counts of making threats against the President.
- An initial examination concluded that Ryan was not competent to stand trial but could likely attain competency with treatment.
- On January 16, 2019, a court ordered Ryan to be hospitalized for up to 120 days to determine if his competency could be restored.
- Ryan was designated to the United States Medical Center for Federal Prisoners (MCFP) on March 7, 2019.
- Due to miscommunication and limited bed space, Ryan did not arrive at MCFP until June 27, 2019.
- Ryan's competency evaluation at MCFP ended on October 25, 2019, more than four months after his arrival.
- On March 17, 2020, the court found that Ryan remained incompetent to stand trial and was unlikely to be restored to competency in the foreseeable future.
Procedural Posture:
- Andrew Ryan was charged with making threats against the President in the U.S. District Court for the Middle District of Tennessee (trial court).
- The Tennessee trial court found Ryan incompetent to stand trial and ordered him committed for evaluation under 18 U.S.C. § 4241(d).
- After finding Ryan was unlikely to be restored to competency, the Government filed a petition for civil commitment under 18 U.S.C. § 4246 in the U.S. District Court for the Western District of Missouri, the district where Ryan was confined.
- Ryan moved to dismiss the petition, arguing the court lacked subject-matter jurisdiction due to violations of the § 4241(d) time limits.
- The U.S. District Court for the Western District of Missouri denied Ryan's motion to dismiss and later granted the petition to civilly commit him.
- Ryan (Appellant) appealed the denial of his motion to dismiss to the U.S. Court of Appeals for the Eighth Circuit, with the United States (Appellee) as the opposing party.
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Issue:
Does an alleged violation of the statutory time limits for a competency evaluation under 18 U.S.C. § 4241(d) deprive a different district court of subject-matter jurisdiction to hear a subsequent civil commitment petition under 18 U.S.C. § 4246?
Opinions:
Majority - Gruender, J.
No. An alleged violation of the statutory time limits for a competency evaluation under § 4241(d) does not deprive a court of jurisdiction over a subsequent civil commitment proceeding under § 4246. The court reasoned that the requirement in § 4246(a) that a defendant be 'committed to the custody of the Attorney General pursuant to section 4241(d)' is not a jurisdictional element. Citing Arbaugh v. Y&H Corp., the court explained that for a statutory limitation to be jurisdictional, Congress must clearly state it as such. Since § 4241 and § 4246 do not mention jurisdiction, the time limits are non-jurisdictional claims-processing rules that can be waived. The proper forum to challenge delays in a § 4241(d) custody is the court that ordered it—in this case, the Middle District of Tennessee—not the court hearing the § 4246 civil commitment petition. Because Ryan failed to properly object, appeal, or seek a writ of mandamus regarding the delays in the Tennessee court, he waived his right to challenge the lawfulness of his § 4241(d) custody. Therefore, his motion to dismiss the § 4246 petition, which was based on this waived argument, necessarily fails.
Analysis:
This decision clarifies that time limits in federal competency evaluation statutes are procedural, not jurisdictional, and are therefore subject to waiver. It places the burden on defendants to raise timely objections to procedural errors in the court where they occur, preventing them from using those errors as a collateral attack in a separate, later proceeding. This reinforces the Supreme Court's precedent in Arbaugh, which favors treating statutory requirements as non-jurisdictional unless Congress explicitly provides otherwise, thereby promoting judicial finality and efficiency.
