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FILE - In this Feb. 28, 2012 file photo, Michael Keith Spell arrives at Montana state district court in Sidney, Mont. for a hearing in the case of murdered Montana teacher Sherry Arnold. The Colorado man's bid to avoid trial and a potential death sentence in the killing of an eastern Montana teacher goes before a state judge Monday, March 24, 2014 to decide if the defendant is incompetent due to mental disability. His attorneys say 24-year-old Spell has the mental capacities of a first-grader and is unfit for trial. If Judge Richard Simonton agrees, Spell could be sent to a state institution indefinitely. (AP Photo/Matt Brown, File)

FILE - In this Feb. 28, 2012 file photo, Michael Keith Spell arrives at Montana state district court in Sidney, Mont. for a hearing in the case of murdered Montana teacher Sherry Arnold. The Colorado man's bid to avoid trial and a potential death sentence in the killing of an eastern Montana teacher goes before a state judge Monday, March 24, 2014 to decide if the defendant is incompetent due to mental disability. His attorneys say 24-year-old Spell has the mental capacities of a first-grader and is unfit for trial. If Judge Richard Simonton agrees, Spell could be sent to a state institution indefinitely. (AP Photo/Matt Brown, File)

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