Sell v. United States (2003)

United States Supreme Court

539 U.S. 166

Nature of Case

Whether it is unconstitutional to involuntary medicate defendants solely to render them competent to stand trial.

Facts of Case

Charles Thomas Sell had been a practicing dentist, but he had a history of psychiatric hospitalizations. In September 1982, he told doctors he believed the gold he used for fillings had been contaminated by Communists. He was psychiatrically hospitalized, treated with antipsychotic medication, and released. In June 1984, he called the police and reported a leopard boarded a bus outside his office and asked the police to kill him. He was again hospitalized. He also complained that government officials were trying to kill him and that God told him a soul would be saved for every FBI agent he killed. In May of 1997, Sell was charged with submitting fictitious insurance claims for payment. He was later indicted by a grand jury on 56 counts of mail fraud, 6 counts of Medicaid fraud, and 1 count of money laundering. In April 1998, Sell was indicted for the attempted murder of an FBI agent who had arrested him and a former employee who planned to testify against him in the fraud case. In 1999, Sell requested a competency evaluation, was sent to the U.S. Medical Center, and he was found incompetent. He was ordered to be treated at the U.S. Medical Center for up to four months. After two months, staff recommended he be medicated with antipsychotics, but Sell refused medication. The reviewing psychiatrist recommended involuntary medication, and the administration reviewed and upheld the hearing officer’s decision. Sell contested and a Magistrate judge held a hearing. In August 2000, the Magistrate held that Sell was a danger to himself and others and issued an order authorizing the involuntary administration of antipsychotic medications. The District Court issued an opinion in April 2001, and determined the Magistrate erred in finding Sell dangerous, but affirmed the involuntary medication order. In March 2002, the Court of Appeals affirmed the district court decision. The United States Supreme Court granted certiorari.

Issue

Did the United States Court of Appeals for the Eighth Circuit err in approving forced medication solely for the purpose of rendering the defendant competent to stand trial for non-violent offenses?

 

Holding

In a 6 to 3 decision, the Court vacated the decision of the United States Court of Appeals for the Eighth Circuit. The Court held that the appellate court erred in affirming the district court’s decision, because both courts recognized that Sell was erroneously found dangerous by the Magistrate judge. In an opinion delivered by Justice Breyer, the Court held that the Fifth Amendment Due Process Clause permits the Government to involuntary administer antipsychotic medications to defendants facing serious criminal charges in order to render them competent to stand trial. The Court stated that this would not have to be considered if the defendant met criteria based on dangerousness; however, if the defendant did not meet other criteria, the following requirements must be satisfied in order to involuntarily medicate: important government interests are at stake, medication is substantially likely to restore competence and not impair competence, medication is necessary, and medication is medically appropriate. The Court stated the following:

  • “First, a court must find that important governmental interests are at stake. The Government’s interest in bringing to trial an individual accused of a serious crime is important.”
  • “Second, the court must conclude that involuntary medication will significantly further those concomitant state interests It must find that administration of the drugs is substantially likely to render the defendant competent to stand trial. At the same time, it must find that administration of the drugs is substantially unlikely to have side effects that will interfere significantly with the defendant’s ability to assist counsel in conducting a trial defense, thereby rendering the trial unfair.”
  • “Third, the court must conclude that involuntary medication is necessary to further those interests. The court must find that any alternative, less intrusive treatments are unlikely to achieve substantially the same results.”
  • “Fourth, as we have said, the court must conclude that administration of the drugs is medically appropriate, i.e. in the patient’s best medical interest in light of his medical condition.”

The Court vacated the appellate court decision and remanded the case for further proceedings in accordance with the Court’s findings.

Rationale

The Court concluded that it may be in the Government’s interests to medicate individuals solely to render them competent to stand trial, but protections for the individual must be in place. Before this type of hearing takes place, it should be determined if the individual could be medicated due to dangerousness. If not, then the Government can ask that the individual be medicated to restore him to competence. If this type of hearing does take place, medication can only be administered involuntarily if the above criteria are met.