United States v. Joe Pyatt, Jr.

USCA4 Appeal: 25-6654 Doc: 7 Filed: 02/24/2026 Pg: 1 of 2

UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT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Affirmed by unpublished per curiam opinion.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Unpublished opinions are not binding precedent in this circuit.

USCA4 Appeal: 25-6654 Doc: 7 Filed: 02/24/2026 Pg: 2 of 2

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