U.S. v. Truett

Defendant pleaded guilty to a drug conspiracy charge for his role in running a methamphetamine distribution operation while in jail. During a change-of-plea hearing, defendant notified the district court judge of mental, cognitive, and memory impairments and also provided additional evidence of those impairments and their degree prior to sentencing. On appeal, defendant argued that the district court should have sua sponte held a competency hearing. Defendant also challenged the district court’s sentencing guidelines calculation, arguing that it was based on a drug quantity erroneously attributing to him the entire amount of methamphetamine obtained by the conspiracy. Finally, defendant argued that a condition of supervised release should be vacated because the court included it in the written judgment but failed to orally pronounce it. The Seventh Circuit affirmed, finding that the district court did not err by failing to hold a competency hearing or by attributing all the methamphetamine to the defendant. The Seventh Circuit also declined to vacate the condition of supervised release, explaining that conditions of supervised release included in a written judgment are mandatory. (FLAUM and BRENNAN, concurring)