The U.S. Court of Appeals for the Fourth Circuit affirmed a district court's finding that defendant Travis Keith Lang is incompetent to stand trial in a federal criminal case, according to an unpublished per curiam opinion filed Feb. 6, 2026.
The three-judge panel, consisting of Circuit Judges Harris, Heytens, and Benjamin, upheld the U.S. District Court for the District of South Carolina's order committing Lang to federal custody under 18 U.S.C. § 4241(d)(2) for competency evaluation and potential restoration.
Senior District Judge Cameron McGowan Currie originally determined that Lang suffered from "Delusional Disorder, Mixed type, continuous," which rendered him unable to understand the criminal proceedings against him and assist in his defense. The district court found that while Lang possessed a solid factual understanding of the legal system, he lacked a rational understanding of how it applied to his specific case.
The competency determination was based on the unrebutted testimony of Dr. Lauren Schumacher, a forensic psychologist who conducted a mental health evaluation of Lang. According to the court documents, Dr. Schumacher's assessment revealed that Lang's delusions prevented him from appreciating the nature of the criminal case against him and from meaningfully participating in his defense.
The case originated in the District of South Carolina at Columbia under case number 3:25-cr-00409-CMC-1. Lang appealed the incompetency finding through counsel David Alan Brown Sr. of DABROWNLAW, LLC in Rock Hill, South Carolina. The government was represented by Assistant U.S. Attorney Jonathan Scott Matthews from the U.S. Attorney's Office in Columbia.
Lang's attorney filed an Anders brief, named after the Supreme Court case Anders v. California (1967), which established procedures for counsel who believe an appeal lacks merit. Under Anders, attorneys must file a brief identifying any potentially arguable issues while explaining why the appeal appears frivolous. This procedural move suggests Lang's counsel found no meritorious grounds for challenging the competency determination.
Federal competency standards require that defendants understand the nature and consequences of the proceedings against them and can assist in their defense. Under 18 U.S.C. § 4241, when a court finds a defendant incompetent, it may order commitment to the custody of the Attorney General for up to four months to determine if competency can be restored through treatment.
The statute requires that during this period, the defendant receive appropriate psychiatric or psychological treatment aimed at restoring competency. If competency cannot be restored within the statutory timeframe, additional proceedings may determine the defendant's future custody status.
Delusional disorder is a mental health condition characterized by fixed false beliefs that persist despite evidence to the contrary. The "mixed type" designation indicates that Lang's delusions did not fall into a single category but encompassed multiple types of delusional themes. The "continuous" specification suggests the disorder represented an ongoing condition rather than episodic symptoms.
The Fourth Circuit's decision was issued as an unpublished per curiam opinion, meaning it was decided unanimously by the panel without a single judge writing a named opinion. Unpublished opinions do not establish binding precedent within the Fourth Circuit, though they may have persuasive value in similar cases.
Competency to stand trial represents a fundamental requirement in criminal proceedings, rooted in due process protections. Courts must ensure defendants can meaningfully participate in their defense before proceeding with trial. The distinction between factual understanding and rational understanding proves crucial in these determinations—defendants may know basic legal concepts while remaining unable to apply that knowledge rationally to their situation due to mental illness.
The Fourth Circuit's affirmance suggests the district court properly applied federal competency standards and relied on appropriate expert testimony. The unrebutted nature of Dr. Schumacher's testimony likely strengthened the competency finding, as Lang's defense apparently presented no contrary mental health evidence.
The case highlights the intersection of criminal law and mental health, demonstrating how courts balance defendants' rights with public safety concerns. While competency proceedings may delay criminal cases, they ensure that prosecutions proceed only when defendants can meaningfully participate in their defense.
Lang's case will now proceed according to the federal competency restoration process. If treatment successfully restores his competency, the underlying criminal case may resume. If competency cannot be restored, additional proceedings will determine his long-term custody and treatment needs under federal civil commitment statutes.
The appeal was submitted to the Fourth Circuit on Jan. 26, 2026, and decided just 11 days later, reflecting the relatively straightforward nature of competency appeals when supported by uncontradicted expert testimony.