Sell V. United States - Decision

Decision

Although the Supreme Court upheld two aspects of the appeal, it ultimately vacated and remanded on the question of the petitioner's dangerousness.

• Held

In a divided opinion (6-3), the Court held that the Constitution allows the Federal Government to administer antipsychotic drugs, even against the defendant's will, in limited circumstances as decided previously in Washington v. Harper and Riggins v. Nevada. It affirmed that involuntary administration for the purposes of restoring a defendants competency to stand trial can be an appropriate means of acting in the state's interest to bring to trial defendants who are charged with serious crimes, overriding the defendant's right to refuse forced medication. However, the court outlined specific criteria which must be satisfied to justify involuntary medication. This framework was outlined in Riggins v. Nevada.

1. An important government issue must be at stake and only a case by case inquiry can determine whether the government's interest is mitigated by the possibility of a long civil commitment for the treatment of the mental illness or by the fact that long periods of confinement have already been served, as this would be subtracted from any criminal sentence.
2. There must be a substantial probability that the medication will enable the defendant to become competent without substantial undermining side effects.
3. The medication must be necessary to restore the defendant's competency, with no alternative, less intrusive procedures available that would produce the same results.

he 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.

• Held

The Supreme Court held that the Eighth Circuit Court of Appeals erred in approving the lower court's order to allow forced medication to restore Sell's competence to stand trial because the original decisions of the hospital and the judge were based on an assessment of Sell's dangerousness. Since the experts testifying at the hearings focused mainly on the issue of dangerousness and not on Sell's trial competence, there was not enough evidence in the court record regarding the possible effect of the medication on Sell's ability to obtain a fair trial.

• Vacated and remanded

In examining the lower courts' findings, the Court found no evidence that Sell was dangerous, so the Court assumed that he was not. Determining that the findings of the District Court and Court of Appeals did not satisfy the criteria for involuntary medication, the Court vacated the appellate court's judgment.