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United States v. Renfroe

argued: May 11, 1987.


Appeal from the United States District Court for the District of Delaware, D.C. Crim. No. 86-00023-01.

Gibbons, Chief Judge, Mansmann, Circuit Judge, and Katz, District Judge.*fn*

Author: Mansmann


MANSMANN, Circuit Judge.

This is an appeal from a judgment of conviction, following a jury trial, in which the defendant Adam Renfroe was found guilty of bribery of a witness in violation of 18 U.S.C. § 201(d) and obstruction of justice in violation of 18 U.S.C. § 1503. The defendant challenges the district court's denial of his claim that the conduct of the government was so improper that due process barred the prosecution; the court's admission of testimony regarding an alleged prior bad act by Renfroe; and his conviction under 18 U.S.C. § 1503 on the grounds that the section does not proscribe an attempt to bribe a witness. We find these contentions to be without merit and we will, therefore, affirm with respect to them.

The defendant also challenges the district court's refusal to adjourn sentencing in order to hold a hearing pursuant to 18 U.S.C. § 4241 to ascertain whether Renfroe was competent at trial and at the time of sentencing due to an alleged 16 year cocaine addiction. We find that, on the basis of the evidence presented to the court, there was reasonable cause to believe that Renfroe was not competent to stand trial nor to participate in sentencing. We, therefore, will remand for a determination by the district court as to whether a meaningful hearing on competency can now take place.


Appellant Adam Renfroe is an attorney who was indicted on March 4, 1986, and charged with bribery in violation of 18 U.S.C. § 201(d) and with obstruction of justice in violation of 18 U.S.C. § 1503. A jury convicted Renfroe of both charges.

Questions regarding the issue of Renfroe's competency to stand trial and competency for sentencing purposes were first brought to the attention of the court, not by motion for a competency hearing but through testimony elicited at a post-trial due process and sentencing hearing.*fn1 At that proceeding, Mr. Renfroe's attorneys presented evidence attesting to Mr. Renfroe's long standing cocaine addiction, previous medical and legal problems incurred due to his addiction, and his then current admission to a detoxification center in Georgia.

Dr. Steven Simring, a psychiatrist, testified regarding Renfroe's 16 year cocaine use, Renfroe's denial of his cocaine abuse and addiction, and the defendant's physical problems resulting from the addiction. Dr. Simring also testified to the potential psychological defects which may be associated with habitual cocaine users, and to the fact that Renfroe had begun to respond to treatment for his addiction in the Georgia therapeutic center. The focus of this testimony was to establish the nature of drug addiction and behavioral and other manifestations of addiction in the context first of the due process hearing, and secondly, to support a request to postpone sentencing to allow Mr. Renfroe to complete his detoxification treatment.

During Dr. Simring's direct testimony, the court, sua sponte, raised the issue of Renfroe's competency to stand trial or to participate in the sentencing procedure. At that point counsel for Mr. Renfroe specifically declined to suggest that Renfroe was or had been incompetent at trial. As the proceeding continued, however, counsel elicited more information which bore upon the defendant's incompetence to stand trial and/or participate in the sentencing proceeding. At the close of the government's cross-examination of Dr. Simring, counsel for Mr. Renfroe applied to the court for adjournment of the proceeding to allow Mr. Renfroe to complete the detoxification program and to then "submit the fuller picture in terms of competence and sentencing."*fn2 The government orally opposed these requests.

The court then presented the critical issue to counsel for both sides as ". . . whether I have probable cause to believe that he may be incompetent to testify." After further testimony, the court concluded that ". . . there is no evidence before the court which leads the court to conclude that the defendant is incompetent to proceed during the sentencing procedure. Whether he should be confined for drug addiction, that is an issue separate and apart from his ability to participate in these proceedings." Although it appears that the court may have presented its question to counsel in the context of an application under 18 U.S.C. § 4244 (a motion to determine the present mental condition of a convicted defendant), it is clear that the court's resolution of the issue pertained to Mr. Renfroe's competency to continue with the proceeding at hand. We conclude that the court's decision was directed to a competency hearing under 18 U.S.C. § 4241.


Fundamental to our adversary system of justice, and perhaps especially of criminal justice, is the prohibition against subjecting to trial a person whose mental condition is such that he lacks the capacity to understand the nature and object of the proceedings against him, to consult with counsel, and to assist in preparing his defense. See Drope v. Missouri, 420 U.S. 162, 43 L. Ed. 2d 103, 95 S. Ct. 896 (1975). It is clear that the conviction of a legally incompetent defendant and the failure to provide ...

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