Warren v. GeorgiaAnnotate this Case
Jesse James Warren was indicted on four counts of murder and many additional charges in connection with a mass shooting at a Penske Trucking Company in 2010, in which four victims were killed and a fifth victim was paralyzed. The State gave notice of its intent to seek the death penalty. In 2013, Warren filed a special plea of mental incompetence to stand trial. The trial court issued an order for Warren to be evaluated by the Georgia Department of Behavioral Health and Developmental Disabilities. A report indicated that Warren was incompetent to stand trial but might benefit from treatment. The trial court then issued an order for Warren to be placed in the custody of the Department in order to receive further psychological observation, evaluation, and treatment. In late 2013, the State filed a motion requesting the authority to medicate Warren involuntarily in an attempt to make him mentally competent to stand trial. The court filed a short order granting the State’s motion. Warren appealed that decision to the Supreme Court. After review, the Supreme Court concluded that the trial court’s order was insufficient in numerous respects to justify Warren’s involuntary medication for the sole purpose of making him mentally competent to stand trial for the very serious crimes he was accused of committing. The Georgia Supreme Court vacated the trial court’s order and remanded the case for further proceedings. The Court noted that the since the evidentiary hearing was held, it was possible that Warren’s mental and physical condition had materially changed, and also possible that new scientific information was available regarding antipsychotic drugs and their likely effectiveness and side effects. Consequently, if the State elected to pursue its motion for involuntary medication on remand, the trial court should allow the parties to present additional evidence to ensure that the court’s findings are based on current circumstances.