United States v. Umar Abdulmutallab, 2014 U.S. App. LEXIS 587

Abdulmutallab pleaded guilty to eight counts stemming from the Christmas Day 2009 attempt to detonate a bomb onboard Flight 253.
Pretrial proceedings included standby counsel while Abdulmutallab elected to proceed pro se; the district court found a voluntary waiver of counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency to stand trial	Abdulmutallab contends a competency hearing was required.	Government maintained no competency doubt warranted a hearing.	No error; no reasonable cause to question competence.
Competency to proceed pro se	Waiver to proceed pro se implicitly raised competency concerns.	Standby counsel ensured representation; waiver valid.	No error; waiver valid given standby counsel and no substantial doubt.
Suppression of statements at hospital	Statements should be suppressed as Miranda violation/unduly influenced by pain meds.	Not challenged because plea precludes independent pre-plea suppression claims absent conditional plea.	Waived; pre-plea suppression issues cannot be challenged after guilty plea.
Constitutionality of 18 U.S.C. § 924(c)	§ 924(c) valid as applied to underlying interstate commerce-connected offenses.	Commerce Clause does not authorize § 924(c) as applied here.	As-applied, § 924(c) constitutional; underlying offenses substantially affect interstate commerce.
Eighth Amendment and substantive reasonableness of life sentences	Life sentences for lack of physical harm are excessive under evolving standards of decency.	Deterrence and terrorism justification sustain the punishment.	Sentence within guidelines; not cruel and unusual; substantively reasonable.

Drope v. Missouri, 420 U.S. 162 (1975) (demeanor and behavior may warrant competency inquiry before trial)
Pate v. Robinson, 383 U.S. 375 (1966) (history of mental illness can require competency hearing)
Dusky v. United States, 362 U.S. 402 (1960) (test for competence to stand trial: rational understanding and ability to assist counsel)