United States v. Gamarra, No. 18-3082 (D.C. Cir. 2019)Annotate this Case
Defendant appealed the district court's order authorizing the government to medicate him without his consent for the purpose of rendering him competent to stand trial. Defendant was indicted for threatening bodily harm to the President and for conveying false information concerning the use of an explosive. At issue were the district court's rulings on two of the four Sell factors for determining whether the government had met its burden of proof.
In regard to the second Sell factor, the DC Circuit held that the government established that the administration of the drugs was substantially likely to render defendant competent to stand trial, even if the psychiatrist did not personally examine defendant. Furthermore, the district court did not clearly err in concluding that the prescribed medication was substantially unlikely to cause side effects impairing defendant's ability to assist his counsel. In regard to the fourth Sell factor, the court held that defendant presented no basis for concluding that the district court clearly erred in relying on the psychiatrist to conclude that involuntary medication would be in defendant's best medical interests.