U.S. v. Wessel

Dist. Ct. did not commit clear error in finding that defendant was competent to stand trial on charge of felon in possession of firearm. Dist. Ct. ordered three 45-day evaluations of defendant at urging of his counsel and ultimately found defendant competent, where two government experts diagnosed defendant with substance abuse disorders and agreed that defendant understood nature of proceedings, roles of courtroom players and possible outcomes. Dist. Ct. further held that defendant was reasonably able to assist in his defense, where he chose to speak to some people and engaged in pattern of manipulation. Fact that defendant had some sort mental illness did not preclude finding that defendant was competent to stand trial, and Dist. Ct. did not necessarily enter inconsistent findings when it found that defendant was competent to stand trial, but denied defendant’s attempt to waive jury trial, after finding that said waiver was not knowing and voluntary. Also, fact that defendant had obscene outbursts at trial did not require finding that he was incompetent, where Dist. Ct. could have reasonably concluded that said outbursts were form of maladaptive malingering that was predicted by government experts.