United States v. Steil

The federal government (plaintiff) prosecuted Jeffrey Allen Steil (defendant) for illegal possession of a sawed-off shotgun. Steil had been mentally ill since childhood, but he had no history of violence and no criminal record. In response to Steil's clear display of bizarre and irrational behavior, the federal district court judge initiated a series of standard procedures to determine whether Steil was mentally competent to stand trial. The judge found that Steil was neither presently competent, nor likely to attain competence. The judge's finding triggered the ensuing series of procedures pursuant to 18 U.S.C. § 4246. First, the judge remanded Steil to the attorney general's custody to determine whether Steil could be placed in a suitable government facility. Second, the attorney general reported that no such facility could be found. Third, the government petitioned the judge to commit Steil to a federal facility for an indefinite term of hospitalization and treatment for schizophrenia, on the grounds that Steil's release from federal custody would endanger public safety. Fourth, a federal magistrate held a hearing on the government's petition. The magistrate recommended denying the petition, because experts tended to overestimate a mentally ill patient's propensity for dangerous behavior, and Stein's background showed no evidence of such a propensity. After a de novo review of the record, the judge rejected the magistrate's recommendation and granted the government's petition, finding that the government met its burden of showing by clear and convincing evidence that Steil's release would endanger others. Steil appealed to the Eighth Circuit Court of Appeals.