Reported / Citable
Background
Xavier Jerel Leonard moved on November 2, 2022, for a psychiatric or psychological examination to determine whether a mental disease or defect made him unable to understand the proceedings or assist in his defense. The court granted the motion the next day.
Dr. Lisa Bellah, a licensed psychologist at the Federal Correctional Institution in Fort Worth, evaluated Leonard and concluded that he did not have a mental disease or defect impairing his ability to understand the case or assist counsel. At a June 13, 2023 competency hearing, Leonard appeared with counsel, and neither side objected to the report or its findings.
The Court’s Holding
Magistrate Judge Christine L. Stetson recommended that the district court find Leonard competent to stand trial under 18 U.S.C. § 4241. The report concluded that he had both a rational and factual understanding of the proceedings and could consult with his attorney with a reasonable degree of rational understanding.
The magistrate judge also recommended excluding speedy-trial time from November 2, 2022—the date Leonard sought the examination—through the date the district judge adopts the report and recommendation. The parties had 14 days to file specific written objections.
Key Takeaways
- The unopposed psychological evaluation supported a finding of competency.
- The recommendation applies the standard that a defendant must understand the proceedings and be able to assist in the defense.
- The report recommends excluding the competency-examination period from speedy-trial calculations.
Why It Matters
The ruling is a recommendation, not a final district-court competency determination. If adopted, it permits the criminal case to proceed while excluding the competency-review period from the speedy-trial clock.