United States v. Coy, No. 20-1156 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's grant of the government's motion to begin involuntary treatment of defendant under Sell v. United States, 539 U.S. 166 (2003). Defendant suffers from amphetamine-induced psychotic disorder, with onset during intoxication, and was charged with unlawful possession of a firearm by a convicted felon. The district court found defendant incompetent to stand trial and defendant declined medication.
The court found that the district court did not clearly err in finding that the Treatment Plan will significantly further the important state interests. In this case, the government met its burden in showing that the medication was substantially likely to render defendant competent to stand trial and it was substantially unlikely to have side effects that would interfere significantly with defendant's ability to assist counsel in conducting a trial defense. Finally, the district court did not clearly err in finding that involuntary medication is medically appropriate for defendant.
Court Description: [Shepherd, Author, with Colloton and Wollman, Circuit Judges] Criminal case - Criminal law. The district court's order permitting involuntary medication of defendant under Sell v. U.S., 539 U.S. 166 (2003) is affirmed; the district court did not err in finding that the involuntary medication would significantly further the state interests in bringing defendant to trial for a serious criminal offense; the evidence showed the medication was substantially likely to render the defendant competent to stand trial and that it was substantially unlikely to have side effect that would interfere significantly with defendant' ability to assist counsel in conducting a trial defense; further the government showed that administration of the drugs was medically appropriate, i.e., in defendant's best medical interest in light of his medical condition.
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