Opinion of The Court
Per curiam, the Supreme Court vacated the lower court's ruling without issuing an opinion. The case was remanded to the Louisiana Supreme Court for further deliberation in view of Washington v. Harper (1990), also a case involving involuntary medication, which had been decided after the District Court's ruling.
Upon remand, the lower court ruled against the forcible medication of individuals in order to maintain their competency for execution. This decision was based on the distinction that, unlike Harper v. Washington which was concerned with involuntary medication for treatment issues, forcing medication for the purposes of execution was not medical treatment (being "antithetical to the basic principles of the healing arts") but punishment.
In addition, the court found two state laws on which to base its holding. First it found that forcibly medicating a person for the purposes of execution was cruel and unusual punishment under Louisiana state law because "it fails to measurably contribute to the social goals of capital punishment" by adding to the individual's punishment "beyond that required for the mere extinguishment of life," and could be "administered erroneously, arbitrarily or capriciously". It also held that forcible medication in this situation violated the right to privacy guaranteed by the Louisiana State Constitution because the inhumanity of the situation rendered the state's interest in executing a person under these conditions less compelling.
Read more about this topic: Perry V. Louisiana
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