United States v. Tiran Casteel
717 F.3d 635
| 8th Cir. | 2013Background
- Casteel and his son Devan Casteel were separately tried and convicted of carjacking, related firearm counts, obstruction of justice, and witness tampering in the first trial, and Casteel was later convicted in a second trial of two felon-in-possession counts for firearms; sentencing followed separately for the two trials.
- Darlene Eitzen, a 76-year-old widow, was robbed at gunpoint in September 2008 by the Casteels at her Iowa home; coins and other items were later traced to the Eitzen robbery and coin shop transactions.
- Undercover ATF agents arranged firearm purchases by Casteel, and firearms were recovered from the Casteels’ vehicle; coins later connected to the Eitzen robbery were seized during the investigation.
- Evidence included Casteel’s recruitment of accomplices, a “back way” map to Eitzen’s house, internet searches about Eitzen and coins, and communications indicating attempts to influence a potential witness.
- Dr. Rogers and Dr. Nieberding provided competing competency assessments; the district court ultimately found Casteel competent for sentencing after a competency hearing in 2011.
- Casteel was sentenced to 319 months for the first trial convictions and 63 months on each felon-in-possession count (concurrent with each other and with the prior sentence).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retroactive competency determination authority | Casteel argues the court should have ruled on retroactive competency. | Government contends no abuse of discretion; retroactive ruling unnecessary. | Not reversible error; court did not abuse discretion. |
| Competency to stand trial and to be sentenced | Casteel contends he was not competent; expert opinions favored by Rogers. | Court credited Nieberding’s competence finding. | Court did not err; Casteel competent to stand trial and be sentenced. |
| Sufficiency of evidence for felon in possession | Casteel claims possession was fleeting/innocent. | Evidence showed purposeful possession or control. | Sufficient evidence supported conviction. |
| suppression of Bonneville search under Fourth Amendment | Search of car violated Fourth Amendment; Gant applicable. | Search valid under pre-Gant standards and existing precedent. | District court did not err in denying suppression. |
| Sentencing grouping and criminal history points | Errors affected substantial rights. | Harmless given concurrent sentencing. | Harmless; no remand needed. |
Key Cases Cited
- Pate v. Robinson, 383 U.S. 375 (U.S. 1966) (requires competency hearings when reasonable cause exists)
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (standard for competency to stand trial)
- United States v. Rickert, 685 F.3d 760 (8th Cir. 2012) (discusses competency and related standards)
- United States v. Ghane, 593 F.3d 775 (8th Cir. 2010) (district court may choose between experts’ opinions)
- United States v. Turner, 644 F.3d 713 (8th Cir. 2011) (consideration of behavior and history in competency determinations)
- Davis v. United States, 564 U.S. _, 131 S. Ct. 2419 (U.S. 2011) (pre-Gant searches and reliance on precedent)