United States of America v. Mandle Lee Martin

Nashville, Tennessee criminal defense lawyer represented the Defendant charged with felony possession of a firearm and ammunition.



FBI agents arrested Martin for receiving and possessing ammunition as a convicted felon.

Between his May 2018 arrest and his December 2022 guilty plea, Martin's behavior caused his

counsel and the district court to question his mental competence. At counsel's request, the district

court twice ordered psychological evaluations of Martin—once in 2018 and again in 2021. Both

evaluations concluded that Martin could understand the nature of the criminal proceedings, and

both opined that at least some of Martin's lack of cooperation in his legal proceedings appeared to

be volitional. After each evaluation, the district court held a competency hearing, pursuant to

18 U.S.C. § 4241, and concluded that Martin was competent to proceed.



Martin ultimately pleaded guilty, pursuant to a plea agreement, to one count of receipt and

possession of ammunition by a convicted felon. The district court found Martin "competent to

enter a plea of guilty” and accepted the plea. Before sentencing, Martin's counsel filed a

sentencing memorandum stating that, although he believed that Martin's mental health had

"seriously deteriorated” since the change-of-plea hearing, he knew of "no legal authority for a

further competency hearing after the defendant has entered a guilty plea and is awaiting

sentencing.”



At sentencing, the district court calculated Martin's Guidelines range at 140–175 months.

And after considering Martin's mental health as a mitigating factor, the district court sentenced

Martin to a below-Guidelines sentence of 130 months' incarceration. The court recommended that

the Bureau of Prisons place Martin in a federal medical facility so that he could receive mental-

health treatment. This appeal followed.

Wh

Affirmed