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United States of America v. Bonny L. Reynolds

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Before Boudin, Circuit Judge, Souter, *fn1 Associate Justice, and Stahl, Circuit Judge.

A grand jury charged Bonny Reynolds with knowingly possessing two firearms after having been committed to a mental institution, in violation of 18 U.S.C. § 922(g)(4); and, because the serial number on one of the firearms was obliterated, knowingly possessing a firearm with an obliterated serial number, in violation of 18 U.S.C. § 922(k). After the district court determined that she was sufficiently competent, Reynolds opted for what became a one-day bench trial and was found guilty as charged. The district court sentenced Reynolds to a two-year term of imprisonment followed by three years’ supervised release. Reynolds raises four issues on appeal, all of which relate, at least in part, to her competency. Specifically, she argues that, because of her mental infirmities, (1) she should not have been found competent to stand trial, (2) she did not voluntarily consent to the firearms search, (3) the judge could not be impartial and should have recused himself, and (4) she did not voluntarily waive her right to a jury trial. We affirm.

I. Background

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