United States v. Larson
1:24-cr-00130
| D. Colo. | Oct 9, 2024Background
- Defendant Daniel Larson is charged with multiple federal offenses related to explosives and threats; he has been detained since arrest in May 2024.
- A forensic psychiatric evaluation determined Larson is not currently competent to proceed or waive trial rights.
- On July 26, 2024, the court ordered Larson committed to the custody of the Attorney General for psychiatric treatment and competency restoration in a suitable facility, for up to four months per 18 U.S.C. § 4241(d).
- By September 25, 2024, Larson had not been transferred; the Bureau of Prisons had assigned a facility but indicated no bed was available until December 2024.
- Larson moved for immediate transfer, arguing his rights under the Insanity Defense Reform Act (IDRA) and the Speedy Trial Act were being violated by the delay.
Issues
| Issue | Larson's Argument | Gov't Argument | Held |
|---|---|---|---|
| When does the § 4241(d) four-month cap begin? | Cap begins from court order; deadline expiring soon | Cap begins upon hospitalization, not court order | Period starts upon hospitalization; no current violation |
| Delay in hospital transfer ("pre-hospitalization" detention) | Delay unreasonable, merits transfer/dismissal | Delay due to bed shortages, not unreasonable (yet) | Five-month delay not yet unreasonable; monitored |
| Speedy Trial Act violation | Clock will expire soon due to unjustified delay | Clock tolled for incompetency and valid delays | Clock tolled; no Speedy Trial violation |
| Remedy if delay continues | Immediate transfer or case dismissed | Not addressed directly | Will consider dismissal if not transferred by 12/31/24 |
Key Cases Cited
- Jackson v. Indiana, 406 U.S. 715 (statute only permits commitment for a reasonable period to determine competency)
- U.S. v. Magassouba, 544 F.3d 387 (statutory restoration period begins upon hospitalization)
- U.S. v. Donnelly, 41 F.4th 1102 (long pre-hospitalization confinement can violate statutory rights)