United States v. White, No. 19–6181 (4th Cir. 2019)
Nature of Case: Appellee was charged with sex offenses, but found incompetent to stand trial and was released. Appellee was again charged with sex offenses, though remained incompetent to stand trial. Fact of incompetence notwithstanding, United States petitioned to civilly commit Appellee as a dangerous sex offender. Trial court dismissed the proceedings against Appellee, finding that he was unable to participate in his defense, that the court had the ability to dismiss a civil commitment proceeding against an incompetent person, and that to allow the commitment proceeding to go forward in this case would violate Appellee’s procedural Due Process rights. United States sought review.
Holding: 4th Circuit Court of Appeals reversed and remanded, holding that the provision of law that authorizes the commitment proceedings do not authorize a district court to dismiss those proceedings on the grounds of mental incompetence. Furthermore, allowing commitment proceedings against someone who is adjudged to be mentally incompetent does not violate Due Process.