Jeffrey Henry Williamson v. United States

Congress, in a comprehensive set of statutes, 18 U.S.C. §§ 4241-4248, provided procedures and standards for examinations and detention of federal defendants suffering from various mental health issues. In § 4246(a), Congress provided for the civil commitment of certain persons, including those such as petitioner. The statute sets forth the procedures for determining whether the person should be committed, which are triggered when the “director of a facility in which a person is hospitalized certifies that a person in the custody of the Bureau of Prisons”: against whom all criminal charges have been dismissed solely for reasons related to the mental condition of the person, is presently suffering from a mental disease or defect as a result of which his release would create a substantial risk of bodily injury to another person or serious damage to property of another, and that suitable arrangements for State custody and care of the person are not available. That certification is sent to the clerk of the district court “for the district in which the person is confined” for commitment proceedings. The filing of a certificate “stay[s] the release of the person pending the completion of procedures contained in this section.” No certificate was filed in the present case, yet the district court presiding over Mr. Williamson’s criminal case ordered his commitment for an examination to allow the director of the BOP facility to determine whether to issue a certificate to initiate commitment proceedings. That order raises the question presented: Whether the district court can, contrary to the plain language of the statute, order an examination of a person under 18 U.S.C. § 4246 where the director of the facility in which the person is confined has not filed any certificate to commence § 4246 proceedings.