US v. Danny Roney
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The Fourth Circuit held that 18 U.S.C. § 4243 allows a district court to revoke an insanity acquittee’s conditional discharge only when the acquittee fails to comply with the court-approved prescribed treatment regimen, not merely when an ‘ancillary’ release condition is violated. Applying that interpretation, the court nevertheless affirmed the revocation of Danny Roney’s conditional discharge because the firearm-possession restriction he broke was part of his certified treatment regimen.
Circuit Split Identified
Legal Issue
Whether 18 U.S.C. § 4243 allows a district court to revoke an insanity acquittee’s conditional discharge based on violation of an ancillary condition unrelated to the prescribed treatment regimen, or only for non-compliance with the prescribed regimen of medical, psychiatric, or psychological care or treatment.
Circuit Positions
Revocation may be based on violation of ancillary conditions beyond the prescribed treatment regimen.
Revocation is limited to failures to comply with the prescribed regimen of medical, psychiatric, or psychological care or treatment; ancillary-condition violations cannot justify revocation.
Conflict Summary
The First, Seventh, Eighth and Ninth Circuits read § 4243 (and its sister statutes) broadly, permitting courts to impose ‘ancillary’ conditions and to revoke conditional release when those ancillary conditions are violated. The Eleventh Circuit—now joined by the Fourth Circuit in this opinion—reads the statute narrowly, holding that revocation is authorized only when the acquittee fails to comply with the prescribed treatment regimen itself; ancillary-condition violations cannot trigger revocation.