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2024 Supreme(US)(ca11) 175

COURT OF APPEALS FOR THE ELEVENTH CIRCUIT
United States – Appellant
Versus
Haitham Alhindi – Respondent



[PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 23-11349 ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus HAITHAM YOUSEF ALHINDI,

Defendant- Appellant.

____________________

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:22-cr-80085-AMC-1 ____________________

Before ROSENBAUM, NEWSOM, and LUCK, Circuit Judges. USCA11 Case: 23-11349 Document: 80-1 Date Filed: 04/01/2024 Page: 2 of 32

2 Opinion of the Court 23-11349

PER CURIAM: Mental competence is the key to a criminal defendant’s abil- ity to unlock the value of his constitutional trial rights. Indeed, without mental competence, a defendant cannot take advantage of “the right to effective assistance of counsel, the rights to summon, to confront, and to cross-examine witnesses, and the right to testify on one’s own behalf or to remain silent without penalty for doing so.” Riggins v. Nevada, 504 U.S. 127, 139–40 (1992) (Kennedy, J., concurring). For that reason, the Supreme Court has recognized that trying only mentally competent defendants “is fundamental to an adversary system of justice.” Drope v. Missouri, 420 U.S. 162, 171–72 (1975). And sometimes, defendants may need medical treatment to attain this essential competence. At the same time, involuntary hospitalization for mental- health treatment “constitutes a significant deprivation of liberty.” Addington v. Texas, 441 U.S. 418, 425 (1979). So “due process re- quires that the nature and duration of commitment bear some rea- sonable relation to the purpose for which the individual is commit- ted.” Jackson v. Indiana, 406 U.S. 715, 738 (1972). Federal law attempts to balance these concerns, among oth- ers. Towards that end, 18 U.S.C. § 4241 sets forth the procedures for determining a defendant’s competency to stand trial and ad- dressing any incompetency. This case raises two questions about how we apply § 4241. First, we must decide whether the statute permits a court to order more than one competency hearing and commitment order for the USCA11 Case: 23-11349 Document: 80-1 Date Filed: 04/01/2024 Page: 3 of 32

23-11349 Opinion of the Court 3

same defendant in a single case. Second, we must determine what exactly the four-month limitation in § 4241(d)(1) restricts: the de- fendant’s commitment to the Attorney General under the district court’s commitment order or the defendant’s hospitalization. On the first question, we conclude that district courts have authority to order more than one competency evaluation and com- mitment order. This text-based conclusion protects both the de- fendant’s right not to be tried while incompetent and the defend- ant’s right to avoid unnecessary hospitalization. As for § 4241(d)(1)’s four-month limitation, we hold that, by § 4241(d)(1)’s terms, the period begins with the defendant’s hospitalization. Applying these rules here, we determine that the district court’s second commitment order did not violate § 4241 and was not othe

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