U.S. v. Anzaldi

In prosecution on charges of conspiracy to file false income tax returns and filing false claims based upon scheme alleging existence of sovereign citizen theory arising out of belief that govt. held hidden bank counts that were accessible by its citizens, Dist. Ct. did not err in declining to sua sponte hold competency hearing for one defendant who represented herself at trial. Defendant had no history of mental illness, and although govt. described some of her statements in her pre-trial motions as “nonsensical” and standby counsel referred to defendant’s behavior as “delusional,” Dist. Ct. did not have reasonable cause to believe that defendant suffered from mental disease that prevented her from understanding nature of proceedings against her, where: (1) all purported evidence of mental illness stemmed from defendant’s decision to pursue discredited legal defense; and (2) defendant’s adherence to discredited legal theory does not create reasonable cause to believe she suffered from mental defect. Moreover, Dist. Ct. could rely on defendant’s and her standby counsel’s statements affirming defendant’s ability to understand charges against her, as well as defendant’s performance at trial in which she advanced nuanced legal arguments to negate element of charged offense.