United States v. Andrew Ryan, 52 F.4th 719

Andrew Ryan was charged in the Middle District of Tennessee with making threats against the President and was found incompetent to stand trial under 18 U.S.C. § 4241.
The Middle District ordered hospitalization and evaluation under § 4241(d); logistical delays (designation, bed availability) led to a prolonged evaluation period at the U.S. Medical Center for Federal Prisoners in Springfield, Missouri.
The Middle District later concluded Ryan remained incompetent and unlikely to be restored, and ordered a § 4246 evaluation to determine civil commitment.
While Ryan was confined in Missouri, the Government filed a § 4246 petition in the Western District of Missouri seeking civil commitment; the warden certified the statutory prerequisites.
Ryan moved to dismiss, arguing the § 4241(d) timing limits were violated—so he was not lawfully “committed to the custody of the Attorney General pursuant to section 4241(d)” and the Western District lacked jurisdiction; the district court denied the motion and granted civil commitment.
On appeal, Ryan argued statutory timing violations and due-process defects; the Eighth Circuit affirmed, holding the jurisdictional challenge was waived and the timing requirement is nonjurisdictional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 4241(d)’s timing requirements are jurisdictional such that a timing violation defeats a later § 4246 petition	Ryan: The § 4241(d) timing limits must be met; because more than four months lapsed, he was no longer committed pursuant to § 4241(d), so § 4246 jurisdiction is lacking	Government: Timing in § 4241(d) is not jurisdictional; § 4246(a)’s reference to commitment under § 4241(d) is waivable and challenges belong to the court that ordered § 4241(d) custody	The timing requirement is nonjurisdictional; Arbaugh framework applies and the challenge can be waived
Whether Ryan preserved or waived his timing/due-process challenge to § 4241(d) custody	Ryan: He raised delay complaints in status updates, asserting speedy-trial and due-process violations	Government: Ryan failed to seek relief or appeal in the Middle District of Tennessee (the proper forum) and thus waived the challenge	Ryan waived the challenge by not raising it timely in the court that ordered § 4241(d) custody; the Western District was not the appropriate forum to adjudicate those timing claims

Arbaugh v. Y&H Corp., 546 U.S. 500 (statutory limitations are jurisdictional only if Congress clearly says so)
United States v. Zaic, 744 F.3d 1040 (standard of review — de novo for dismissal of § 4246 petition)
United States v. Mooring, 287 F.3d 725 (timing requirement treated as nonjurisdictional and subject to waiver)
Heuton v. Ford Motor Co., 930 F.3d 1015 (application of traditional waiver and forfeiture principles)
United States v. Curbow, 16 F.4th 92 (proper forum to contest § 4241(d) delays is the court that ordered the commitment)
United States v. Ferro, 321 F.3d 756 (collateral-order appeal route for contesting incompetency-commitment rulings)
United States v. Ecker, 30 F.3d 966 (requirement that civil commitment under § 4246 occur in the district where the individual is confined; discussion of due-process arguments)