United States of America v. Joe Nathan Pyatt, Jr.

UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 25-6654
UNITED STATES OF AMERICA,
Petitioner - Appellee,
v.
JOE NATHAN PYATT, JR.,
Respondent - Appellant.
Appeal from the United States District Court for the Eastern District of North Carolina, at
Raleigh. James C. Dever III, District Judge. (5:23-hc-02209-D)
Submitted: February 19, 2026 Decided: February 24, 2026
Before WYNN and HARRIS, Circuit Judges, and TRAXLER, Senior Circuit Judge.
Affirmed by unpublished per curiam opinion.
Joe Nathan Pyatt, Jr., Appellant Pro Se. Genna Danelle Petre, Special Assistant United
States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North
Carolina, for Appellee.
Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:
Joe Nathan Pyatt, Jr., appeals the district court’s order denying his Motion to
Dismiss Certificate and Proceedings. We have reviewed the record and find no reversible
error. See, e.g., McKaskle v. Wiggins, 465 U.S. 168, 183 (1984) (holding that a defendant
has no right to proceed with a hybrid form of representation); United States v. Wayda, 966
F.3d 294, 308 (4th Cir. 2020) (recognizing that the “additional reasonable period of time”
under 18 U.S.C. § 4241(d) “should not be so short as to not accord the government
reasonable time to seek and file [a] certification,” but directing government to certify
“individuals in a time frame that . . . minimizes the time spent as an incompetent,
unrestorable person”). Accordingly, we affirm the district court’s order. United States v.
Pyatt, No. 5:23-hc-02209-D (E.D.N.C. July 25, 2025). We dispense with oral argument
because the facts and legal contentions are adequately presented in the materials before this
court and argument would not aid the decisional process.
AFFIRMED

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