Abstract
Jane, a 32-year-old individual, is facing federal criminal charges for an alleged white-collar offense that has a maximum punishment of one year in prison. On March 1, 2019, the court decides to assess Jane’s mental competency to stand trial due to concerns raised in the initial proceedings. The court, relying on the standards set forth by the United States Supreme Court,1 initiates a hearing to determine whether sufficient evidence exists to warrant a mental competency evaluation. After the competency hearing, the court concludes that there is a need for such a mental evaluation. Jane is then sent for an initial competency determination.2 After that first assessment, the court finds Jane mentally incompetent on April 1, 2019, and orders her to undergo competency restoration treatment.3 In accordance with the Insanity Defense Reform Act (“IDRA”), the court, having found Jane incompetent, commits her to the custody of the attorney general.4 The IDRA explicitly mandates a reasonable period of hospitalization, not to exceed four months, for the mental health treatment that will help Jane gain the capacity to proceed to trial.5 However, administrative delays and logistical challenges result in Jane’s waiting nine months in a state jail to receive the necessary mental health treatment. When Jane finally enters the hospital on January 1, 2020, the court starts the four-month mandatory timeline to rehabilitate Jane pursuant to the IDRA. However, the nine-month delay in Jane’s case contradicts the intent of the IDRA, which seeks to prevent the extended detention of defendants deemed incompetent.6 Jane could now be held in pretrial detention for an entire year, potentially exceeding the length of time of her sentence had she been competent and found guilty at the outset of the charges against her. Complicating the problem, the Speedy Trial Act (“STA”) requires a federal criminal defendant’s trial to commence within seventy days of the indictment.7 This substantial delay in providing Jane with a mental evaluation, together with any mental health treatment that she might need, raises questions about whether certain exceptions to the STA for defendants found mentally incompetent might delay Jane’s trial indefinitely.8 As discussed in detail in this Note, the STA excludes time from the seventy-day clock for the following reasons: delays that result from proceedings or examinations related to the defendant’s competency; delays due to the defendant’s incompetency; and delays in transporting a defendant to a hospital for examination, in which case only ten days are considered reasonable.9 The STA was designed to protect defendants’ rights to a speedy trial10 by expediting the criminal justice process and decreasing the backlog in federal courts. Jane’s extended wait for mental health treatment challenges these core principles.
Recommended Citation
McInroe, Bridgette
(2025)
"Clearing the Legal Fog: Navigating Conflicting Interpretations of the Speedy Trial Act and the Insanity Defense Reform Act for Mentally Incompetent Defendants,"
University of Memphis Law Review: Vol. 55:
Iss.
3, Article 3.
Available at:
https://digitalcommons.memphis.edu/um-law-review/vol55/iss3/3