Sell v. United States
| Sell v. United States | |
|---|---|
|
|
| Argued March 3, 2003 Decided June 16, 2003 |
|
| Full case name | Charles Thomas Sell, Petitioner v. United States |
| Citations | 539 U.S. 166 (more)
123 S. Ct. 2174; 156 L. Ed. 2d 197; 2003 U.S. LEXIS 4594; 71 U.S.L.W. 4456; 188 A.L.R. Fed. 679; 2003 Cal. Daily Op. Service 5131; 2003 Daily Journal DAR 6512; 16 Fla. L. Weekly Fed. S 359
|
| Prior history | Order granting permission to administer drug No. 4: 98CR177, (E.D. Mo. Aug. 9, 2000);Order affirmed 2001 U.S. Dist. LEXIS 26009 (E.D. Mo., Apr. 4, 2001); affirmed by 8th Cir. court at 282 F.3d 560 |
| Subsequent history | remanded to district court 343 F.3d 950, 2003 U.S. App. LEXIS 26859 (8th Cir., Sept. 2, 2003) |
| Holding | |
| Drugs to make defendant competent to stand trial may be administered involuntarily under very limited circumstances. | |
| Court membership | |
| Case opinions | |
| Majority | Breyer, joined by Rehnquist, Stevens, Kennedy, Souter, and Ginsburg |
| Dissent | Scalia, joined by O’Connor and Thomas |
| Laws applied | |
| U.S. Const. amend. VI, XIV | |
Sell v. United States, 539 U.S. 166 (2003) is a landmark decision in which the United States Supreme Court imposed stringent limits on the right of a lower court to order the forcible administration of antipsychotic medication to a criminal defendant who had been determined to be incompetent to stand trial for the sole purpose of making them competent and able to be tried. Specifically, the court held that lower courts could do so only under limited circumstances in which specified criteria had been met. In the case of Charles Sell, since the lower court had failed to determine that all the appropriate criteria for court-ordered forcible treatment had been met, the order to forcibly medicate the defendant was reversed.
Previously, in Washington v. Harper 494 U.S. 210 (1990), the Supreme Court made clear that the forced medication of inmates with mental disorders could be ordered only when the inmate was a danger to themselves or others and when the medication is in the inmate's own best interests. In addition, courts must first consider "alternative, less intrusive means" before resorting to the involuntary administration of psychotropic medication.
Using the framework set forth in Riggins v. Nevada 504 U.S. 127 (1992), the Court emphasized that an individual has a constitutionally protected "interest in avoiding involuntary administration of antipsychotic drugs" and this interest is one that only an "essential" or "overriding" state interest might overcome.
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.
...
Wikipedia