United States v. Curtis, No. 13-2085 (8th Cir. 2014)
Annotate this CaseDefendant was found incompetent to stand trial after he was indicted on one count of possession of a firearm after having been committed to a mental institution. The district court ordered defendant to be involuntarily medicated to restore him to competency. The court held that the district court did not err in finding that the government had satisfied the second Sell v. United States factor: that involuntary medication would significantly further the government's important interest in prosecuting the case. In the absence of a specific determination by the district court whether administering the medication constituted a medically appropriate treatment for defendant, as required by the fourth Sell factor, there was no finding for the court to review. Therefore, the court remanded with directions that the district court determine whether the government had established by clear and convincing evidence that involuntarily administering the recommended medication regime to defendant was medically appropriate.
Court Description: Criminal case - Criminal law. In a case involving involuntary medication of the defendant to restore his competency to stand trial, the government's evidence established the second factor identified in Sell v. United States, 539 U.S. 106 (2003) -that administration of the drug risperidone would significantly further the government's interest in prosecuting the case - but the district court failed to make a specific determination with respect to the fourth Sell factor - whether administering the drug constituted a medically appropriate treatment for defendant - and the matter must be remanded with directions to the district court to determine whether the government has established by clear and convincing evidence that involuntarily administering the medication is medically appropriate. [ April 14, 2014
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