## Facts

- George James Dockins was tried in the Northern District of Mississippi for (1) possessing a firearm as a convicted felon under 18 U.S.C. § 922(g)(1) and (2) making a false statement to acquire a firearm under 18 U.S.C. § 922(a)(6).
- Dockins used the name “Carl Smith” in connection with vehicle repairs at a Clarksdale, Mississippi garage and later in purchasing a shotgun at Wal-Mart, including signing ATF Form 4473 and denying a felony conviction.
- After an incident in which Dockins drove away from the garage with the foreman’s objections, police stopped him for speeding and arrested him; an inventory search found a pistol, a sawed-off shotgun, and a credit-card slip reflecting a shotgun purchase by “Carl Smith.”
- After Miranda warnings, Dockins admitted purchasing the pistol, using a VISA card under “Carl Smith,” and signing “Carl Smith” on the federal firearms form while answering “no” to the felony-conviction question.
- To prove the prior-felony element, the government introduced a Colorado judgment of conviction for robbery for “Carl Tyron Smith” and Denver police records including a fingerprint card and police record sheet.
- The defense objected that the Denver police records were not properly authenticated; the trial court found they were not self-authenticating under Federal Rule of Evidence 902 but admitted them under Rule 901 based on testimony linking the signature and fingerprints on the card to Dockins.
- During trial, Dockins engaged in disruptive behavior and sought relief based on alleged incompetency; the district court declined to declare a mistrial or hold an additional competency hearing after earlier competency evaluations.

## Issues

1. Whether the district court erred in finding Dockins competent to stand trial, denying a mistrial, and declining to conduct another competency hearing in light of his trial behavior.
2. Whether the government presented competent evidence that Dockins was a convicted felon, including whether the Denver police fingerprint and record documents were properly authenticated under Rules 901–902.

## Decision

- The Fifth Circuit affirmed the convictions.
- The court held the district court did not clearly err or abuse its discretion in its competency determinations, denial of a mistrial, or refusal to conduct an additional competency hearing.
- The court held the evidence was sufficient to prove Dockins’s felon status and that the district court did not abuse its discretion by admitting the Denver police records under Rule 901 despite lack of Rule 902 self-authentication.

## Legal Principles

- Competency under 18 U.S.C. § 4241(d) turns on whether a defendant can understand the proceedings and assist counsel; appellate review gives substantial deference to the trial judge’s observations and is highly constrained by clear-error/abuse-of-discretion standards.
- A defendant is not entitled to a mistrial or repeated competency proceedings when the trial court reasonably finds the defendant’s disruptive conduct is deliberate misconduct aimed at provoking a mistrial rather than evidence of inability to proceed.
- Failure to satisfy Rule 902 self-authentication (e.g., absence of seal or proper certification for public records) does not bar admission if Rule 901(a) is satisfied.
- Under Rule 901(a), authentication requires evidence sufficient to support a finding that the item is what the proponent claims; testimony and circumstantial evidence, including identity links via signatures and fingerprint comparison, can authenticate law-enforcement records.
- When authenticated records and a judgment of conviction connect the defendant to an alias used in the conviction documents, the jury may find the prior-felony element proven beyond a reasonable doubt for §§ 922(g)(1) and 922(a)(6).

## Conclusion

The Fifth Circuit upheld Dockins’s firearms convictions, deferring to the trial court’s competency and mistrial rulings and holding that uncertified police records lacking Rule 902 formalities were admissible under Rule 901 where testimony and fingerprint evidence supported a finding that the documents were authentic and linked Dockins to a prior felony conviction.


United States v. Dockins, 986 F.2d 888 (5th Cir. 1993)