United States v. Steil
United States Court of Appeals for the Eighth Circuit
916 F.2d 485 (1990)
Jeffrey Allen Steil (defendant), charged with illegally possessing a sawed-off shotgun, had been mentally ill since childhood but had no history of violence or criminal record. After Steil displayed bizarre behavior, the trial judge found him incompetent to stand trial and unlikely to become competent, triggering the procedures of 18 U.S.C. § 4246: the attorney general could not find a suitable facility for Steil, so the government petitioned to commit him indefinitely for schizophrenia treatment, arguing his release would endanger public safety. A magistrate recommended denying the petition, noting experts tend to overestimate dangerousness and Steil's own history showed none, but the judge rejected that recommendation after a de novo review and granted the commitment, finding clear and convincing evidence Steil's release would endanger others. Steil appealed.
Whether federal law authorizes the indefinite hospitalization of a person whose mental illness or defect creates a substantial risk of harm to the person or property of another.