One of the first Federal cases linking competency with the U.S. Constitution was Youtsey v. United States (1899). Youtsey suffered from a seizure disorder and had been tried in absentia (Not being present at the event (trial)) for embezzlement. The case was eventually overturned by the Sixth Circuit Court of Appeals as Youtsey’s memory and mind were impaired and he was incapable of appreciating his situation and intelligently advising his counsel in his own defense. The Court noted, “Does the mental impairment of the prisoner’s mind, if such there be, whatever it is, disable him . . . from fairly presenting his defense, whatever it may be, and make it unjust to go on with his trial at this time, or is he feigning to be in that condition”.