District Court Failed to Explain Why Defendant with Low IQ, Delusions, Could Be Medicated to Competency

U.S. v. Valenzuela-Puentes, 2007 WL 766273 (3/15/07) - An involuntary medication victory. The 10th held the d.ct. failed to explain why it was convinced the defendant could be rendered competent through medication, despite his exceptionally low IQ (73 & 76) and entrenched delusional thought patterns (the government employed him as a "federal runner" and he was a citizen of a single country composed of the U.S., Mexico and Canada)(does that inspire some new defenses?). Also, it was not clear the d.ct. had required the government to meet its clear and convincing burden. The 10th did say the prosecution of a reentry case served an important government interest based on the length of the statutory maximum sentence, even though the offense was nonviolent. The 10th expressed unease with the defendant's three-and-a-half-year pretrial detention.