United States v. Williams
| Decision Date | 17 November 2022 |
| Docket Number | 22-6464 |
| Parties | UNITED STATES of America, Petitioner - Appellee, v. Nathaniel WILLIAMS, Respondent - Appellant. |
| Court | U.S. Court of Appeals — Fourth Circuit |
ARGUED: Jennifer Claire Leisten, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Raleigh, North Carolina, for Appellant. Genna Danelle Petre, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellee. ON BRIEF: G. Alan DuBois, Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Raleigh, North Carolina, for Appellant. Michael F. Easley, Jr., United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellee.
Before RICHARDSON and HEYTENS, Circuit Judges, and MOTZ, Senior Circuit Judge.
Vacated and remanded by published opinion. Judge Heytens wrote the opinion, in which Senior Judge Motz joined. Judge Richardson wrote a dissenting opinion.
Federal prisoners on the cusp of being released may be civilly committed if they are "presently suffering from a mental disease or defect as a result of which [their] release would create a substantial risk" to the person or property of others. 18 U.S.C. § 4246(d). Here, the primary question is whether—in making such a risk assessment—a court must consider any terms of supervision that would govern the prisoner's conduct post release. The answer, we hold, is yes. And because the record offers no assurances the district court appropriately considered the terms of Nathaniel Williams’ supervised release before ordering him committed, we vacate the court's order and remand for further proceedings.
Williams has long struggled with mental illness and a proclivity to violent outbursts. In 2017, Williams assaulted a security guard in Portland, Oregon—a federal crime because it happened at a Social Security office. See 18 U.S.C. § 111(a)(1). Williams pleaded guilty and was sentenced to just over four years in prison, to be followed by three years of supervised release. The sentencing court imposed 13 standard and 14 special conditions of supervised release, including that Williams "must take all mental health medications that are prescribed by [his] treating physician" and "must participate in a mental health treatment program." JA 128.
For several years, Williams did not fare well in federal custody. In March 2019, he was transferred to a medical center in Minnesota after failing to take medication, experiencing mania and hallucinations, and assaulting his cellmate. Even after the transfer, Williams continued to rack up incident reports and failed to reliably take prescribed medication. After more than a year of new incidents—and Williams’ formal request to withdraw from voluntary mental health treatment—the government successfully petitioned to have Williams hospitalized under 18 U.S.C. § 4245, which permits the involuntary transfer of a federal prisoner who "is presently suffering from a mental disease or defect" "to a suitable facility for care and treatment." § 4245(a) & (d).
Having secured the involuntary hospitalization order, Bureau of Prisons officials concluded Williams met the constitutional and regulatory criteria for involuntary medication. See Washington v. Harper , 494 U.S. 210, 110 S.Ct. 1028, 108 L.Ed.2d 178 (1990) ; 28 C.F.R. § 549.46(a)(5) & (b). In June 2021, Williams began receiving monthly injections of Haldol, which "psychiatrically stabilized" Williams and "remitt[ed]" his symptoms. JA 43, 47. Since starting Haldol injections, Williams has engaged in no violent behavior.
Three months before Williams’ custodial sentence was set to expire, the Bureau of Prisons transferred him to a specialized facility in North Carolina to assess whether he could be safely released. The evaluating psychologist acknowledged that, at the time of intake, Williams displayed no overt signs of a formal thought or mood disorder and his medications had largely remitted his past symptoms. The evaluating psychologist, though, concluded that releasing Williams would create a substantial risk of injury to people or property because she thought Williams would stop taking his medication, which would, in turn, render him dangerous to others.
Less than two weeks before Williams’ scheduled release, the government asked a district court in North Carolina (commitment court) to order him civilly committed. The government's request automatically stayed Williams’ release, see 18 U.S.C. § 4246(a), and the commitment court held a hearing at which Williams, the evaluating psychologist, and a psychiatrist selected by Williams testified. Williams also provided the judgment of the sentencing court, which included the terms of his supervised release.
During the hearing, several points of common ground emerged. First, Williams suffers from schizoaffective disorder, bipolar type, which is in partial or full remission. Second, Williams has a history of seemingly indiscriminate acts of violence when unmedicated. Third, while on his current medication—which he had been taking for more than nine months on an involuntary basis at the time of the hearing—Williams poses no substantial threat to others.
The issue thus came down to whether Williams was likely to continue taking his medication if released. See JA 115 (commitment court stating, "I don't think the Government would dispute" that Williams is "not a danger as long as he complies with his medication"). Williams acknowledged his past failures to take prescribed medication but testified he enjoyed the effects of Haldol, wanted to keep taking it, and likely would be reincarcerated if he failed to do so. By contrast, the evaluating psychologist concluded Williams was unlikely to keep taking his medication if released, citing his earlier probation violations, past inability to stick to medications, and lack of insight into the seriousness of his mental illness.
After the parties presented their evidence, the commitment court asked whether it could order Williams’ release under "conditions which would assure his lack of dangerousness," JA 116, and recessed the hearing so the parties could formulate positions on the matter. When the hearing resumed, the parties agreed that a court considering whether to halt a person's release under Section 4246(d) may not impose new conditions without first committing the person to the custody of the Attorney General.
The parties diverged, however, on whether the commitment court should consider the terms of supervised release imposed by the sentencing court. Williams urged the commitment court to do so, noting that his terms of supervised release included "numerous conditions that directly speak to the [commitment court's] concerns." JA 136. Williams particularly emphasized terms requiring him "to sign a waiver that allows the probation officer to receive all medical information" and thus verify "if he took his [Haldol ] shot." JA 136–37. By contrast, the government insisted that "[t]he supervised release conditions should not impact [the commitment court's] decision." JA 149. Indeed, the government asserted the commitment court should not even "consider" those conditions because "we cannot base our determination on the actions of another court." Id.
At the end of the hearing, the commitment court orally granted the government's request to commit Williams to the custody of the Attorney General. Consistent with the parties’ agreement, the court determined it lacked authority "to order a conditional release of a person who has not been committed ... under the statute." JA 154. The commitment court briefly referenced Williams’ arguments about the conditions of his supervised release:
JA 157.
Six days later, the commitment court issued a written order memorializing its decision. The order reiterated Williams’ release would pose a danger only "if he is unmedicated," JA 162, and acknowledged the parties’ differing positions about the relevance of Williams’ supervised release. See JA 161 ( that Williams "argues that the conditions of supervised release imposed in his criminal case, to which he would be subject if he were not committed, mitigate any risk of danger," whereas "[t]he government contends that [Williams’] supervised release terms should not impact this court's determination"). The order did not comment on the persuasiveness of these arguments, nor did it explain whether—or how—Williams’ supervised release factored into the commitment court's decision. We review the district court's factual findings for clear error and its legal analysis de novo. United States v. Bell , 884 F.3d 500, 507 (4th Cir. 2018).
Repeating its position before the commitment court, the government at first insisted on appeal that a commitment court need not—and perhaps even may not—consider "any term of supervised release" imposed by a sentencing court. Gov't Br. 34. Although the government walked back its claim somewhat during oral argument, we reject that view in all its forms.
We start, as always, with the statutory text. Section 4246(d) does not authorize the involuntary commitment of any person "suffering from a mental disease or defect" or one whose "mental disease or defect" could pose a danger to others under some circumstances. 18 U.S.C. § 4246(d). Instead, the...
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United States v. Tucker
... ... Involuntary ... medication orders "carry an unsavory pedigree," and ... prolonged pretrial detention of a presumptively innocent ... person "is serious business." Chatmon , 718 ... F.3d at 374 (first quote); United States v ... Williams , 53 F.4th 825, 832 (4th Cir. 2022) (second ... quote). Given the deferential standards of review, we ... conclude the district court committed no reversible error in ... deciding an involuntary medication order was warranted and ... finding it appropriate to grant one final ... ...