Criminal Procedure — involuntary medication

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United States Court of Appeals For the Seventh Circuit

Criminal

Criminal Procedure — involuntary medication

Where the district court deferred to the evaluating psychiatrist, the court’s order that a defendant be involuntarily medicated must be vacated.

“When the Government seeks to medicate involuntarily a defendant solely for the purpose of rendering the defendant competent to stand trial, however, it must meet a higher standard to counterbalance the defendant’s right to avoid involuntary medication. Sell, 539 U.S. at 181-82. In Sell, the Court set forth four findings that the district court must make before ordering the involuntary administration of psychotropic medication for the purpose of rendering a defendant competent to stand trial. First, the district court must determine ‘that important governmental interests are at stake’ based on the facts of the individual case. Id. Second, the court must find that the medication ‘is substantially likely to render the defendant competent to stand trial’ and ‘is substantially unlikely to have side effects that will interfere significantly with the defendant’s ability to assist counsel in conducting a trial defense.’ Id. at 181. ‘Third, the court must conclude that involuntary medication is necessary to further those interests’ and ‘that any alternative, less intrusive treatments are unlikely to achieve substantially the same results.’ Id. ‘Fourth, … 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.’ Id. The Government must establish each of these conditions by clear and convincing evidence. United States v. Chatmon, 718 F.3d 369, 374 (4th Cir. 2013); United States v. Ruiz-Gaxiola, 623 F.3d 684, 692 (9th Cir. 2010) (collecting cases). We review the district court’s conclusions of law de novo and its findings of fact for clear error. United States v. Lyons, 733 F.3d 777, 782 (7th Cir. 2013); United States v. Gutierrez, 704 F.3d 442, 448 (5th Cir. 2013). “Without a clear statement of the court’s rationale … , we cannot evaluate whether [the court’s] decision was proper or constituted clear error.” United States v. Hawk, 434 F.3d 959, 962 (7th Cir. 2006).”

Vacated and Remanded.

13-3281 U.S. v. Debenedetto

Appeal from the United States District Court for the Northern District of Illinois, Castillo, J., Ripple, J.