United States v. Terrence Mitchell

JERRY E. SMITH, Circuit Judge:

Terrence Mitchell appeals the revocation of his conditional release under 18 U.S.C. § 4243(g), arguing that the district court erred by not sua sponte ordering a competency hearing at his § 4243(g) hearing; by denying his request for new counsel; and by revoking his conditional release on a finding that he was a substantial risk of bodily injury to others. We affirm.

I

Congress enacted the Insanity Defense Reform Act of 1984 to establish an affirmative defense of insanity, a verdict of “not guilty only by reason of insanity,” and a corresponding civil-commitment…