United States v. Davis
United States Court of Appeals for the Seventh Circuit
764 F.3d 690 (2014)
Margaret Davis (defendant) pleaded guilty to skimming about $377,000 from roughly $1,062,000 she had raised for public health programs. Her presentence report showed she suffered mental disorders requiring hospitalization during and shortly after the offense, and recommended the judge treat that condition as relevant under 18 U.S.C. § 3553(a)(1) and the sentencing guidelines' mitigation provisions. Davis filed extensive briefing and expert statements on her mental condition; at the nine-page sentencing hearing the judge referenced her mental condition six times and imposed 41 months — below the guidelines range but at the high end of her plea agreement's range. Davis appealed, arguing the judge gave inadequate consideration to her mental condition.
Whether the impact of mental illness on a convicted defendant's criminal behavior is a factor that may mitigate the defendant's sentence.