United States v. Carol Woodard
744 F.3d 488
| 7th Cir. | 2014Background
- Woodard, a nonprofit administrator, was indicted for health care fraud related to $8.9 million in false Medicaid claims.
- She faced multiple counsel changes and a sua sponte competency examination due to concerns about understanding proceedings.
- A 2010 competency evaluation found her competent to stand trial; she later voluntarily sought a second competency review in 2012.
- In 2012, Woodard pled guilty after a Rule 11 colloquy and was sentenced to 80 months under the 2011 Guidelines.
- The district court later used the 2011 Guidelines, applying an 97–121 month range, instead of the 2007 range, due to a post‑crime law change.
- On appeal, Woodard challenges (i) denial of a second competency evaluation, (ii) voluntariness of the guilty plea, and (iii) Ex Post Facto sentencing error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there abuse of discretion in denying a second competency evaluation? | Woodard argues ongoing mental decline warranted reevaluation. | Woodard contends doubts about competency persisted and needed further review. | No abuse; no bona fide doubt justified a second evaluation. |
| Was the guilty plea knowing and voluntary? | Woodard asserts red flags were ignored in the Rule 11 colloquy. | Court conducted thorough inquiry; medication did not impair understanding. | Guilty plea knowing and voluntary; no plain error. |
| Did the district court violate the Ex Post Facto Clause at sentencing? | Sentence should reflect the version of the Guidelines at crime time, not sentencing time. | Prevailing Seventh Circuit law allowed sentencing under later Guidelines. | Ex Post Facto violation; remand for resentencing under correct Guidelines. |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) ( Defines competency to stand trial)
- United States v. Andrews, 469 F.3d 1121 (7th Cir. 2006) (no need for second competency absent bona fide doubt)
- United States v. Collins, 949 F.2d 921 (7th Cir. 1991) (objective test for reasonable doubt of competency)
- United States v. Ross, 501 F.3d 702 (7th Cir. 2004) (relevant standard for competency and understanding proceedings)
- United States v. Blalock, 321 F.3d 686 (7th Cir. 2003) (totality of circumstances in Rule 11 colloquy)
- Demaree v. United States, 459 F.3d 791 (7th Cir. 2006) (Ex Post Facto and sentencing timing framework)
- Peugh v. United States, 133 S. Ct. 2072 (S. Ct. 2013) (Ex Post Facto prohibits use of post‑crime Guidelines when harsher)
- United States v. Williams, 2014 WL 486244 (7th Cir. 2014) (remand for resentencing under Peugh framework)
- O'Connor, 874 F.2d 483 (7th Cir. 1989) (appeal ongoing; review principles during proceedings)