United States v. Kidd
- Paul Magnuson
- 0:18-cv-02825
- U.S. District Court · District of Minnesota
- 5
In United States v. Kidd, Judge Magnuson granted the government’s petition to commit Kidd for treatment until treatment ended or his sentence expired.
Patrick Kidd was ordered committed to the custody of the United States Attorney General for hospitalization and treatment. The commitment must end when he no longer needs custody for care and treatment or when his sentence expires, whichever occurs earlier.
What happened
In United States v. Kidd, Patrick Kidd objected to a recommendation that he be committed for hospitalization and treatment under federal law. Kidd had schizophrenia, and medical staff said he needed additional treatment and could not function safely in the general prison population.
The court reviewed Kidd’s objections and agreed that he needed custody for care or treatment and that FMC-Rochester was suitable. The court also added that his commitment must end when he no longer needed treatment or when his prison sentence expired, whichever came first.
Judge Paul A. Magnuson overruled Kidd’s objections in part and sustained them in part, adopted the magistrate judge’s report and recommendation, granted the government’s petition, and ordered Kidd committed to the custody of the United States Attorney General for hospitalization and treatment.
The detailed version
- United States v. Kidd · No. 0:18-cv-02825
- Paul Magnuson
- Feb. 28, 2019
Background
Patrick Kidd had pleaded guilty in 2011 to conspiracy to possess crack cocaine with intent to distribute and was serving a 120-month prison sentence. The Bureau of Prisons calculated his good-conduct release date as August 19, 2019. He had been housed at FMC-Rochester since July 2018.
Kidd was diagnosed with a delusional disorder in 2016 and schizophrenia in 2017. The opinion describes delusions, disorganized thinking and behavior, auditory hallucinations, and increasingly aggressive conduct toward corrections officers and other inmates. Medical staff reported that antipsychotic medication helped but that Kidd needed a higher dosage, different medications, and hospitalization. They also said he needed treatment to improve his condition and prepare for his release.
The United States filed a petition under 18 U.S.C. § 4245(a) seeking a hearing on Kidd’s mental condition. Magistrate Judge Katherine M. Menendez held a hearing and recommended that Kidd be committed to the custody of the United States Attorney General for hospitalization and treatment. Kidd filed objections.
Legal standard and analysis
Section 4245(a) permits involuntary commitment when there is reasonable cause to believe that an imprisoned person has a mental disease or defect for which the person needs custody for care or treatment in a suitable facility. The court identified three questions: whether Kidd had a mental disease or defect, whether he needed custody for care or treatment, and whether FMC-Rochester was suitable.
After independently reviewing the parts of the report and recommendation to which Kidd objected, the court agreed that the medical evidence established that Kidd had schizophrenia. The court also found that he needed treatment because his symptoms interfered with his ability to function in the general prison population and because his refusal to accept the full recommended treatment limited his improvement. The court found FMC-Rochester suitable because it was an accredited hospital offering medical and therapeutic services to incarcerated people.
Ruling
The court overruled Kidd’s objections in part and sustained them in part. It adopted the report and recommendation and granted the government’s petition. The court ordered that Kidd be committed to the custody of the United States Attorney General for hospitalization and treatment until he no longer needed custody for care and treatment or until his prison sentence expired, whichever occurred earlier. The court ordered judgment entered accordingly.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.