7th Circuit Court of Appeals
United States of America v. Martin J. Jonassen
U.S. District Court, Northern District of Indiana, Hammond Division, Judge James T. Mood.
Criminal. Affirms convictions and sentence for kidnapping and obstruction of justice. The District Court properly declined to conduct a competency hearing. Although Jonassen asserted bizarre legal theories based on his claim of “sovereign citizenship,” that alone does not provide a reason to doubt his competence to stand trial, and the record does not otherwise suggest that he lacked the ability to understand the proceedings. The court’s evidentiary ruling was also sound. The government laid an ample foundation for admission of the hearsay statements under Rule 804(b)(6); the evidence established that Jonassen used bribery, guilt and various forms of psychological intimidation to procure his daughter’s unavailability. Finally, because he did not request Jencks Act material before the close of trial, his claim for relief under the Act necessarily fails.