Fourth Circuit: No Civil Commitment at Release for Federal Prisoner in North Carolina Without Considering Conditions
by Casey J. Bastian
On November 17, 20222, the U.S. Court of Appeals for the Fourth Circuit stopped the federal Bureau of Prisons (BOP) from civilly committing a prisoner being released from the Federal Medical Center (FMC) in Butner, North Carolina. Proceeding under 18 U.S.C. § 4246, the government argued that Nathanial Williams posed a “substantial risk” unless confined in a state psychiatric hospital upon release. But the Court said, in effect, not so fast. BOP must first convince the commitment court that the conditions of Williams’ supervised release made it more likely that he would go off his antipsychotic medication and hurt himself or others.
Williams assaulted a security guard at a Portland Social Security Office in 2017 – making him guilty of a federal crime. He was sentenced to four years in federal prison, followed by three years of supervised release. One of the conditions imposed at sentencing was that Williams, who has long struggled with mental illnesses that makes him prone to violent behavior when unmedicated, “must participate in a mental health treatment program.”
In March 2019, after he discontinued his medications and assaulted his cellmate, Williams was transferred to the FMC in Rochester, Minnesota. While there, he continued to get written up for incidents sparked by his on-again/off-again adherence to his medication regimen.
After a year of this, the government had Williams hospitalized under 18 U.S.C. § 4245 et seq, which permits involuntary transfer of a federal prisoner “presently suffering from a mental disease or defect … for care or treatment in a suitable facility.” BOP then began giving Williams monthly injections of Haldol to stabilize and remit his symptoms. Williams engaged in no further violent behavior after the involuntary injections began.
Three months before Williams’ scheduled release, the government transferred him to FMC-Butner and moved the federal court for the Eastern District of North Carolina for his civil commitment upon release. At the commitment hearing, it was determined that Williams suffers from “schizoaffective disorder, bipolar type, which is in partial or full remission,” with a history of “indiscriminate acts of violence when unmedicated.”
At the district court, all parties agreed Williams “poses no substantial threat to others” while medicated. Williams agreed that he enjoyed the Haldol, wanted to take it, and realized that he would likely be reincarcerated if he stopped taking it after release. But the government argued that Williams’ past failures to stay on medication made it unlikely that supervised release alone – still under the jurisdiction of the federal court in Oregon – could ensure his safety or the safety of others. Williams was then involuntarily committed.
On appeal at the Fourth Circuit, Williams was represented by attorneys from the federal public defender’s office. They argued that the district court erred by not considering the terms of Williams’ mandatory supervised release before determining that he was likely to go off his medication unless involuntarily committed. The Court agreed.
The district court’s written order failed to address whether those terms were in fact considered, the Court noted. However, “before prolonging a person’s loss of liberty,” it said that all relevant evidence must be considered, including “other preexisting restrictions on the person’s conduct.” Accordingly, the commitment order was vacated and the case remanded. See: U.S.A. v. Williams, USCA (4th Cir.), Case No. 22-6464 (2022).
The case has now returned to the district court, and PLN will update developments as they are available. See: U.S.A. v. Williams, USDC (E.D.N.C.), Case No. 5:21-hc-02244.
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