## Facts

- Hector Ramirez was prosecuted in federal court for cocaine-related offenses, including possession and conspiracy to possess cocaine with intent to distribute.
- The government’s principal witness was Karla Espinal, an alleged co-conspirator testifying pursuant to a plea agreement.
- Espinal admitted heavy cocaine use during the time period relevant to the charged conspiracy and was taking prescribed Xanax at trial.
- Ramirez argued Espinal’s drug history and medication use could have impaired her mental condition so severely that she was not competent to testify.
- The defense moved to compel a court-ordered psychiatric examination of Espinal to determine competency.
- The district court denied the motion, allowed Espinal to testify, and Ramirez was convicted.

## Issues

1. Whether the district court abused its discretion by denying a defense motion to compel a psychiatric examination of a key government witness based on past drug abuse and current prescription medication use.
2. Under the Federal Rules of Evidence, whether alleged drug-related mental impairment concerns witness “competency” or instead bears primarily on credibility and weight for the jury.

## Decision

- The Sixth Circuit affirmed Ramirez’s convictions.
- The court held the district court did not clearly abuse its discretion in refusing to order a psychiatric examination of Espinal.
- The court concluded Espinal’s past cocaine use and current Xanax use, without a stronger showing of incapacity, did not render her incompetent to testify.
- The court emphasized that credibility concerns were appropriately addressed through cross-examination and jury evaluation.

## Legal Principles

- Federal Rule of Evidence 601 establishes a broad presumption that persons are competent to testify unless the rules provide otherwise.
- “Competency” under the Federal Rules is primarily status-based; categorical incompetency is expressly imposed on judges (Rule 605) and jurors (Rule 606).
- Drug use, medication, and mental condition generally affect credibility and weight, not competency, absent evidence the witness cannot provide meaningful testimony.
- Federal Rule of Evidence 603 permits exclusion if a witness cannot understand or meaningfully take an oath or affirmation to testify truthfully.
- Federal Rule of Evidence 403 authorizes exclusion of testimony when its probative value is substantially outweighed by risks such as unfair prejudice or confusion.
- Decisions to order a mental examination of a witness and to admit or exclude testimony are reviewed for clear abuse of discretion.

## Conclusion

The Sixth Circuit upheld the trial court’s refusal to compel a psychiatric examination of the government’s key witness, holding that prior drug abuse and current medication use raised credibility issues for the jury rather than incompetency under the Federal Rules of Evidence, and that the district court acted within its discretion by permitting testimony subject to cross-examination.


United States v. Ramirez, 871 F.2d 582 (6th Cir. 1989)