United States v. Breedlove, No. 13-3406 (7th Cir. 2014)
Annotate this CaseBreedlove pleaded guilty to drug trafficking and firearms offenses. Before his sentencing hearing, Breedlove filed a “Notice of Ineffective Counsel,” complaining of a conspiracy between his counsel, co-defendants and the court. Breedlove was provided new counsel, who recommended that Breedlove be evaluated for competence. Dr. Szyhowski diagnosed Breedlove as having paranoid schizophrenia. Breedlove was committed to a federal medical facility in Butner, North Carolina. The Bureau of Prisons requested authorization to involuntarily administer antipsychotic medications. At a hearing, the government presented a psychologist and a psychiatrist who jointly authored the report that recommended involuntary medication. In the psychiatrist's opinion, Breedlove’s delusions would remain fixed and prevent him from consenting to medication. Both doctors testified that Breedlove would be closely monitored while at Butner, but acknowledged that when Breedlove was returned to Illinois, they did not know the extent to which he would be monitored. The defense did not call witnesses, but merely submitted testimony from another case that the 79% success-rate figure in the Butner study was too high. The district court granted the request to medicate and denied Breedlove’s motion for reevaluation. The Seventh Circuit affirmed. In Sell v. United States (2003) the Supreme Court determined that to allow involuntary medication, the government must prove by clear and convincing evidence that: important governmental interests are at stake; involuntary medication would significantly further those interests; no viable alternative exists; and administration of the drugs is in the patient’s best medical interest. The district court’s findings were adequate on each factor.
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