U.S. v. Woodward

In prosecution on healthcare fraud charge associated with submission of $8.9 million in false healthcare claims, Dist. Ct. did not err in denying defendant’s request for second competency examination filed shortly before start of her trial. Fact that defendant’s competency had been questioned two years prior to instant request did not generate serious doubts regarding instant request for competency examination, especially where defendant had previously been found competent to assist her counsel, even though defendant had been diagnosed with mental illness. Moreover, medical testimony supported finding that defendant’s medication did not prevent her from understanding court proceedings, and that her mental illness did not prevent her from assisting in her defense throughout four-year period in which defendant interacted with her counsel. Fact that defendant had displayed arguably irrational behavior by terminating several counsel and by filing irrelevant pro se motions did not require different result.