United States v. Jeffrey Allen Steil
916 F. 2d 485 (1990)
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Rule of Law:
An appellate court reviews a district court's finding of dangerousness for the purpose of indefinite civil commitment under 18 U.S.C. § 4246 using the 'clearly erroneous' standard of review.
Facts:
- Jeffrey Allen Steil has a long history of psychiatric problems, including auditory hallucinations starting at age six and two suicide attempts.
- In 1985, after identifying his father as the Green River Killer, Steil killed his puppy, believing it was a threat to his future children, and was subsequently diagnosed with paranoid schizophrenia.
- In late 1987, Steil began a cross-country trip to present his plans for a flying saucer to the government and to track the Green River Killer.
- During the trip, police in Ohio stopped Steil and discovered a loaded, unregistered, sawed-off shotgun on the front seat of his car.
- Steil admitted to the police that he had shortened the barrel of the gun himself.
- When interviewed by federal agents, Steil was agitated, had difficulty maintaining a consistent train of thought, and was unaware that he was in Ohio.
- Steil has also written scores of threatening letters to public figures.
Procedural Posture:
- Steil was charged in the U.S. District Court for the Northern District of Ohio with illegal possession of a sawed-off shotgun.
- The Ohio district court found Steil mentally incompetent to stand trial and committed him to the custody of the Attorney General.
- After determining there was no substantial probability Steil would regain competency, the Ohio district court found his release would create a substantial risk of bodily injury and remanded him to the Attorney General to find a suitable state placement under 18 U.S.C. § 4246.
- After no state placement could be found, the government filed a § 4246 petition in the U.S. District Court for the District of Minnesota, seeking to commit Steil.
- A U.S. Magistrate held a hearing and recommended that the government's petition be denied.
- The U.S. District Court for the District of Minnesota conducted a de novo review, rejected the Magistrate's recommendation, and granted the government's petition, ordering Steil's commitment.
- Steil (appellant) appealed the District Court's order to the United States Court of Appeals for the Eighth Circuit.
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Issue:
Did the District Court err in finding that the government had met its burden of showing by clear and convincing evidence that Steil's release would present a substantial risk of bodily injury to another person or serious damage to the property of another as a result of his mental illness?
Opinions:
Majority - Bowman, Circuit Judge
No. The District Court did not err in finding that the government proved Steil's dangerousness by clear and convincing evidence. First, the court establishes that the proper standard of appellate review for a district court's finding of dangerousness under 18 U.S.C. § 4246 is the 'clearly erroneous' standard, as such a finding is a finding of fact. The court analogizes this to similar factual determinations in bail and competency proceedings which also use this deferential standard. Applying that standard, the court holds that the record amply supports the District Court's finding, as at least five mental health professionals had evaluated Steil and unanimously concluded he was mentally ill and dangerous, with no medical evidence in the record to the contrary. Therefore, the District Court’s finding was not clearly erroneous.
Analysis:
This decision establishes the standard of review for § 4246 civil commitment 'dangerousness' findings within the Eighth Circuit. By adopting the deferential 'clearly erroneous' standard, the court makes it more difficult for individuals to overturn commitment orders on appeal. This places a premium on the factual record and expert testimony presented at the district court level, aligning the review of dangerousness for civil commitment with the review standard used for other liberty-restraining decisions, such as pre-trial detention.
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