United States v. Timothy O'Laughlin

GRASZ, Circuit Judge.

Timothy O'Laughlin argues the district court 1 erred in denying his motion under 18 U.S.C. § 4247 (h). Specifically, he claims to have a Sixth Amendment and statutory right to proceed pro se when seeking discharge from a civil commitment in a proceeding under § 4247(h). But the Sixth Amendment applies only in "criminal prosecutions," U.S. Const., amend VI, and a civil commitment is not a criminal prosecution. And the specific requirements of § 4247(h) control over the general statutory right to proceed pro se. We affirm.

O'Laughlin was civilly committed pursuant to 18…