## Facts

- Jeffrey Allen Steil was charged with federal unlawful possession of an unregistered sawed-off shotgun.
- A court-ordered psychiatric evaluation resulted in findings that Steil was incompetent to stand trial and unlikely to regain competence; he was transferred to a federal medical center.
- The Attorney General reported that no suitable state facility would accept Steil, prompting federal civil-commitment proceedings under 18 U.S.C. § 4246 in the custodial district.
- Steil had a long psychiatric history, including early auditory hallucinations, suicide attempts, repeated hospitalizations, and a diagnosis of paranoid schizophrenia with persistent delusions.
- The firearms offense arose during a cross-country trip in which Steil acted on delusional ideas; police found a loaded, unregistered sawed-off shotgun on the front seat of his vehicle, and agents observed agitation and disorganized thinking.
- At the § 4246 hearing, experts described schizophrenia-associated delusions, impaired judgment, and impulsivity, and opined that unsupervised release created a risk of dangerous conduct.
- A magistrate judge recommended denying commitment, emphasizing the lack of documented violence toward others and cautioning against overestimation of future dangerousness.
- The district court, after de novo review, rejected the recommendation and granted the government’s petition, finding by clear and convincing evidence that Steil’s release would create a substantial risk of bodily injury to others or serious damage to property.

## Issues

1. Whether the district court clearly erred in finding that, due to mental disease or defect, Steil’s release would create a substantial risk of bodily injury to another person or serious damage to another’s property under 18 U.S.C. § 4246.
2. Whether the government proved the § 4246(d) commitment criteria by clear and convincing evidence.

## Decision

- The Eighth Circuit affirmed the order of civil commitment.
- The court held the district court’s dangerousness finding was not clearly erroneous.
- The court held the government met its burden of proof by clear and convincing evidence under § 4246(d).
- The court applied a clearly erroneous standard of review to the district court’s factual determinations regarding mental illness and dangerousness.

## Legal Principles

- Under 18 U.S.C. § 4246, federal civil commitment requires proof that (1) the person suffers from a mental disease or defect and (2) as a result, release would create a substantial risk of bodily injury to another person or serious damage to another’s property, with no suitable state placement available.
- The government’s burden under § 4246(d) is clear and convincing evidence.
- “Substantial risk” under § 4246 may be established without a history of prior violent assaults; the combination of severe mental illness, delusional or disorganized thinking, impaired impulse control, and context such as weapon possession can support the finding.
- On appeal, dangerousness determinations under § 4246 are reviewed for clear error; resolving conflicts in expert testimony is primarily for the district court.

## Conclusion

The Eighth Circuit upheld Steil’s § 4246 commitment because the record supported, by clear and convincing evidence, that his schizophrenia and delusional, impulsive behavior—reinforced by the circumstances of possessing a loaded sawed-off shotgun—created a substantial risk of harm if he were released, and the district court’s findings were not clearly erroneous.


United States v. Steil, 916 F.2d 485 (8th Cir. 1990)