US v. Baldovinos: Baldovinos was convicted by a jury of four drug and firearm counts. Prior to sentencing, he filed motion seeking a competency evaluation at FCI Butner to determine his competency to be sentenced. The district court granted the motion and sent Baldovinos to Butner. Over the course of the next year, physicians at Butner diagnosed Baldovinos as suffering from catatonia and schizophrenia and sought court permission to forcibly medicate him. The district court agreed. The medication never completely "cured" Baldovinos, but physicians began to suspect he was malingering and was thus actually competent to be sentenced. The district court held a sentencing hearing and imposed a 120-month sentence, the statutory minimum given the offenses of which Baldovinos was convicted. Baldovinos failed to object to the imposition of sentence.
Baldovinos appealed, arguing that the district court erred by forcibly medicating him and seeking resentencing.* The Fourth Circuit first concluded that the proper analysis of the issue was under Sell v. US, 539 U.S. 166 (2003), which set forth the ability of courts to forcibly medicate a defendant to render him competent for trial, rather than Washington v. Harper, 494 U.S. 210 (1990), which allowed for the forcible medication of defendants for their own safety. Given that conclusion, the Government admitted error which was plain. However, the Fourth Circuit declined to notice the error, holding that because Baldovinos received the lightest sentence possible he suffered no prejudice and his sentence did not "seriously affect the fairness, integrity or public reputation of judicial proceedings."
*Baldovinos also argued ineffective assistance of counsel, but the court quickly rejected that issue as being "unreviewable at this stage."
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