Sealed v. Sealed, 83 F.4th 399

Appellant (diagnosed with bipolar schizoaffective disorder) threw a Molotov cocktail into a federal office and was federally indicted.
On Dec. 20, 2019 the Southern District of Florida found her incompetent and committed her to the Attorney General under 18 U.S.C. § 4241(d) for hospitalization/treatment.
The court entered a second § 4241(d) commitment on May 8, 2020 (again referencing the statutory four‑month initial examination/treatment period).
On Sept. 4, 2020 the treating psychologist reported Appellant was unlikely to be restored to competency; the Florida court held a final competency hearing on Nov. 3, 2020, found her incompetent and unlikely to be restored, and ordered a dangerousness evaluation for possible § 4246 civil commitment.
The government filed a § 4246 dangerousness certificate and petition in the Northern District of Texas on Dec. 17, 2020 (Appellant was confined at FMC Tarrant); the district court ultimately ordered civil commitment Nov. 1, 2022.
The sole legal question on appeal was whether Appellant remained "committed to the custody of the Attorney General pursuant to section 4241(d)" when the § 4246 petition was filed, thereby authorizing indefinite civil commitment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Appellant was "committed ... pursuant to § 4241(d)" on Dec. 17, 2020 so that § 4246 applied	§ 4241(d)(1)'s four‑month examination/treatment period expired on Sept. 8, 2020, so Appellant was no longer committed under § 4241(d) when § 4246 was filed	Even after the initial four months, § 4241(d)(2) keeps the person committed for an additional reasonable period until (A) restored, (B) charges disposed, or (C) confinement becomes unreasonable; Appellant was not restored, charges were pending, and confinement was not unreasonable	Court held Appellant remained committed under § 4241(d) on Dec. 17, 2020; § 4246 proceedings were authorized
Whether the district court's May 8, 2020 order independently imposed a four‑month cap on the second hospitalization	The May 8 order imposed a four‑month limit on the second hospitalization regardless of statutory subsections	The order merely mirrored the statutory four‑month limit applicable to the initial examination/treatment period and did not impose an independent hard cap; subsequent court and counsel conduct confirmed no such limit	Court held the May 8 order did not impose a hard four‑month cap; continued confinement complied with § 4241(d) and the court's orders

BedRoc Ltd. v. United States, 541 U.S. 176 (statutory text governs unambiguous questions of statutory interpretation)
Sealed Appellee 1 v. Sealed Appellant 1, 767 F.3d 418 (standard of review for statutory construction; procedural context)
United States v. Olano, 507 U.S. 725 (definition and requirements for waiver/forfeiture)
United States v. Arviso‑Mata, 442 F.3d 382 (discussing waiver/forfeiture principles in criminal cases)
United States v. Magassouba, 544 F.3d 387 (§ 4241(d)(2)(B) supports custodial hospitalization when restoration is unlikely and charges remain pending)