Involuntary Medicate-Competency Evaluation

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7^th Circuit Court of Appeals

Case Name: United States of America v. Darlene Fieste

Case No.: 23-1739

Officials: Brennan, St. Eve, and Jackson -Akiwumi, Circuit Judges.

Focus: Involuntary Medicate-Competency Evaluation

Fieste faced charges for making threats to assault and murder two federal judges, three former U.S. presidents, and the current President. Presently, she is considered mentally incompetent to stand trial due to her struggle with delusions. While in custody, Fieste declined the use of antipsychotic medication, even though experts believed that such medication could potentially restore her competence. As a result, the government sought permission to administer involuntary medication with the aim of rendering her competent for trial. However, this order was temporarily halted due to an ongoing appeal.

The Seventh Circuit, in its decision, upheld the need for involuntary medication but sent the case back for further consideration. The court found that Fieste’s pretrial detention wasn’t sufficient to outweigh the government’s interest in prosecution, despite the fact that her anticipated sentencing guideline range was 12-18 months and it was likely that she would receive a sentence equivalent to the time already served if convicted.

Furthermore, the district court was recognized for conducting a comprehensive evaluation to determine that the proposed treatment plan was substantially likely to restore Fieste’s competence and that the potential side effects were unlikely to significantly hinder her participation in the legal proceedings. However, the order lacked specificity by permitting the use of “long-acting injectable antipsychotic medication, along with other medications,” which implied an impermissible level of flexibility in administering unspecified drugs. The Seventh Circuit determined that the district court must specify a dosage range based on the expert’s recommendation or other relevant evidence, either directly within the order or by integrating a sufficiently detailed treatment plan.

Affirmed in part, vacated in part, and remanded.

Decided 10/19/23

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