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Law School Case Brief

Sell v. United States - 539 U.S. 166, 123 S. Ct. 2174 (2003)

Rule:

The Constitution permits the government involuntarily to administer antipsychotic drugs to a mentally ill defendant facing serious criminal charges in order to render that defendant competent to stand trial, but only if the treatment is medically appropriate, is substantially unlikely to have side effects that may undermine the fairness of the trial, and taking account of less intrusive alternatives, is necessary significantly to further important governmental trial-related interests.

Facts:

A Federal Magistrate Judge initially found petitioner Sell, who had a long history of mental illness, competent to stand trial for fraud and released him on bail. However, the Magistrate later revoked bail because Sell's condition had worsened. Sell subsequently asked the Magistrate to reconsider his competence to stand trial for fraud and attempted murder. The Magistrate had him examined at a United States Medical Center for Federal Prisoners, which found him mentally incompetent to stand trial and ordered his hospitalization to determine whether he would attain the capacity to allow his trial to proceed. While there, Sell refused the staff's recommendation to take antipsychotic medication. The medical center authorities decided to allow involuntary medication, which Sell challenged in court. The Magistrate authorized forced administration of antipsychotic drugs, finding that Sell was a danger to himself and others, that medication was the only way to render him less dangerous, that any serious side effects could be ameliorated, that the benefits to Sell outweighed the risks, and that the drugs were substantially likely to return Sell to competence. When the Magistrate's decision was questioned in court, the District Court found the Magistrate's "dangerousness" finding to be "clearly erroneous," but concluded that medication was the only viable hope of rendering Sell competent to stand trial and was necessary to serve the Government's interest in obtaining an adjudication of his guilt or innocence. On appeal, the Eighth Circuit affirmed the district court judge. Focusing solely on the fraud charges, it found that the Government had an essential interest in bringing Sell to trial, that the treatment was medically appropriate, and that the medical evidence indicated a reasonable probability that Sell would fairly be able to participate in his trial.

Issue:

Did the appellate court err in approving forced medication solely to render an accused competent to stand trial?

Answer:

Yes

Conclusion:

The United States Supreme Court assumed that Sell was not dangerous. Based on that hypothetical assumption, the United States Supreme Court found that the appellate court was wrong to approve forced medication solely to render Sell competent to stand trial. The experts focused mainly on the dangerousness issue to the exclusion of other important issues such as trial-related side effects and risks that could have helped determine whether forced medication was warranted on trial competence grounds alone. As a result, there was not enough information to know whether the side effects of the antipsychotic medication were likely to undermine the fairness of the trial in Sell's case.

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