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UNITED STATES v. GRAY (2021)

United States Court of Appeals, Eighth Circuit.2021-09-03No. No. 21-1425

Summary

Holding. The court affirmed the district court's commitment order, concluding that the finding of mental illness and need for treatment was supported by a preponderance of the evidence and was not clearly erroneous.

Dewayne Gray challenged a district court order committing him to the custody of the Attorney General for mental health treatment under federal statute. The commitment was to last until Gray no longer required treatment or his prison sentence expired, whichever came first. Two psychologists who examined Gray both concluded he met the criteria for commitment, and the district court found the commitment decision was supported by sufficient evidence under the required legal standard.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether commitment under 18 U.S.C. § 4245 was supported by a preponderance of the evidence
  • Whether the district court's finding was clearly erroneous
  • Whether Gray met criteria for commitment to the Attorney General's custody for hospital treatment

Procedural posture

Gray appealed a district court order committing him for mental health treatment under federal statute.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

[Unpublished]

Dewayne Gray appeals an order committing him under 18 U.S.C. § 4245 to the custody of the Attorney General for hospital care and treatment until he no longer needs treatment or his prison sentence expires, whichever occurs first. Upon careful review of the record, including the reports of two examining psychologists who opined that Gray met the criteria for commitment, we conclude the district courts 1

§ 4245 finding was supported by a preponderance of the evidence, and was not clearly erroneous. See 18 U.S.C. § 4245(d) (burden of proof and determination of mental illness and treatment need); United States v. Bean, 373 F.3d 877, 879 (8th Cir. 2004) (standard of review). The judgment of the district court is affirmed. FOOTNOTES

1

.   The Honorable Douglas Harpool, United States District Judge for the Western District of Missouri, adopting the report and recommendation of the Honorable David P. Rush, United States Magistrate Judge for the Western District of Missouri.

PER CURIAM.