Sell V. United States - Facts of The Case

Facts of The Case

In 1997, Charles Thomas Sell, a St. Louis dentist with no prior history of criminal behavior, was charged with fifty-six counts of mail fraud, six counts of Medicaid fraud, and one count of money-laundering. That year a federal judge found Sell competent to stand trial and released him on bail. However, Sell's mental status deteriorated while he was on bail, and his bail was revoked in 1998. Also in 1998, on the basis of a videotape provided by an undercover agent, Sell was charged with one count of conspiring to commit the attempted murder of the Federal Bureau of Investigation officer arresting him. The agent later interviewed Sell in jail, and by questioning got him to say something about hiring a hit man. In early 1999 Sell requested a competency hearing before standing trial for the fraud and attempted murder charges.

Sell was given a competency evaluation by the United States Medical Center for Federal Prisoners (Medical Center), and in 1999 was found incompetent to stand trial. Sell was ordered to be hospitalized to determine whether he would be able to become competent so as to allow his trial to proceed. While in the hospital, Sell refused to take the antipsychotic medication prescribed by the Medical Center staff. The Medical Center sought to involuntarily medicate Sell. On June 9, 1999, an administrative hearing was held before a medical hearing officer who concluded that antipsychotic medication was the treatment of choice based on the fact that Dr. Sell's "delusional thinking could make him dangerous." Sell filed a court challenge to stop the hospital's decision to give him the drug involuntarily.

The question of whether the drug could be administered involuntarily was the subject of several other hearings. In August 2000 the magistrate found that Sell was a danger to himself and others, authorized Sell to be forcibly medicated on the grounds that only medication would reduce his dangerousness, that any serious side effects could be treated, that the benefits to Sell were greater than the risks, and that the medication were substantially likely to restore Sell's competence.

In 2001, Sell appealed on certiorari to the Federal District Court which, while reversing the federal magistrate's finding of dangerousness, upheld the order of forced medication on the grounds that it was necessary to restore Sell's competency to stand trial. The Eighth Circuit Court of Appeals affirmed the lower court's decision in a divided vote. Sell's attorney pointed out that Sell had already been incarcerated for a longer period of time than if he were convicted for the offenses as charged.

Sell, on Writ of Certiorari, appealed to the United States Supreme Court. The American Psychological Association filed an amicus curiae brief taking a neutral position, supporting neither the government's nor Sell's position.