Riggins v. Nevada

Facts of the Case

When petitioner Riggins, while awaiting a Nevada trial on murder and robbery charges, complained of hearing voices and having sleep problems, a psychiatrist prescribed the antipsychotic drug Mellaril. After he was found competent to stand trial, Riggins made a motion to suspend the administration of Mellaril until after his trial, arguing that its use infringed upon his freedom, that its effect on his demeanor and mental state during trial would deny him due process, and that he had the right to show jurors his true mental state when he offered an insanity defense. After hearing the testimony of doctors who had examined Riggins, the trial court denied the motion with a one-page order giving no indication of its rationale. At Riggins’ trial, he presented his insanity defense and testified, was convicted, and was sentenced to death. On appeal, the state supreme court affirmed the conviction and held that expert testimony presented at trial was sufficient to inform the jury of Mellaril’s effect on Riggins’ demeanor and testimony.

Question

Does the forced administration of antipsychotic drugs during trial violate the Sixth and Fourteenth Amendments?

CONCLUSION

Yes. Justice Sandra Day O’Connor delivered the opinion of the 7-2 majority. The Supreme Court held that an individual has the right to freedom from an unwanted antipsychotic drug. In order for the state to administer an antipsychotic drug against the patient’s wishes, the state must establish the pressing need for the administration of the drug. Because the district court did not reach a finding on the necessity of the Mellaril, the Court held that its administration was an error that infringed on Riggins’ constitutional rights.In Justice Anthony M. Kennedy’s concurring opinion, he wrote that the Due Process Clause prohibits the state from administering unwanted psychotic drugs to a defendant in order to make the defendant competent to stand trial. He argued that, since the administration of the antipsychotic drug can significantly alter the demeanor of the defendant during the trial and on the stand, it can amount to a manipulation of evidence by the state.Justice Clarence Thomas wrote a dissent where he argued that the issue of whether or not the state should have issued the antipsychotic medication without Riggins’ consent is a separate legal issue from his trial. He argued that there was no evidence that the Mellaril rendered Riggins’ trial anything less than “full and fair,” and therefore Riggins was not entitled to have his conviction reversed. Because he was found to be competent to stand trial under the influence of Mellaril, the Mellaril could not have significantly interfered with his ability to take part in his own defense. Justice Thomas also argued that, since Riggins approached the jail psychiatrist for medication because he was hearing voices, the district court did not order Riggins to take the Mellaril. Justice Antonin Scalia joined in the dissent.

Case Information

  • Citation: 504 US 127 (1992)
  • Argued: Jan 15, 1992
  • Decided May 18, 1992Granted: Oct 7, 1991