Riggins v. Nevada

PETITIONER: David Riggins
RESPONDENT: Nevada
LOCATION: Clark County Detention Center

DOCKET NO.: 90-8466
DECIDED BY: Rehnquist Court (1991-1993)
LOWER COURT: Supreme Court of Nevada

CITATION: 504 US 127 (1992)
ARGUED: Jan 15, 1992
DECIDED: May 18, 1992
GRANTED: Oct 07, 1991

ADVOCATES:
James Tufteland - on behalf of the Respondent
Mace J. Yampolsky - on behalf of the Petitioner

Facts of the case

On November 20, 1987, Paul Wade was found dead in his apartment with multiple stab wounds to his chest, head, and back. Forty-five hours later, David Riggins was arrested and charged with the murder. A few days after being taken into custody, Riggins complained to Dr. R. Edward Quass, the psychiatrist who treated patients in jail, that he was hearing voices. Dr. Quass prescribed the antipsychotic drug Mellaril and, when the voices did not stop, gradually increased the dosage. In January of 1988, Riggins successfully moved for determination of his competence to stand trial, and he was found to be competent. As the trial moved forward, Riggins moved to suspend his treatment with Mellaril because he planned to offer an insanity defense at trial and asserted that he had the right to show the jury his true mental state. The district court denied Riggins motion. Riggins was found guilty and sentenced to death. The Nevada Supreme Court affirmed.

Question

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

Media for Riggins v. Nevada

Audio Transcription for Oral Argument - January 15, 1992 in Riggins v. Nevada

Audio Transcription for Opinion Announcement - May 18, 1992 in Riggins v. Nevada

William H. Rehnquist:

The opinions of the Court in two cases will be announced by Justice O'Connor.

Sandra Day O'Connor:

The first of these is Riggins versus Nevada No. 90-8466, and the case comes to us on certiorari to the Supreme Court of Nevada.

Shortly after being taken into custody on murder and robbery charges the petitioner, David Riggins, complained to a psychiatrist about hearing voices and having trouble sleeping.

The psychiatrist prescribed the antipsychotic drug Mellaril.

Later, the defense attorney moved to suspend the administration of Mellaril during Riggins' trial.

After taking testimony from doctors who had examined Riggins, the Trial Court denied the motion without explaining its reasons for doing so.

Riggins was convicted of murder and robbery, and sentenced to death.

The Nevada Supreme Court affirmed.

We granted certiorari to decide whether the forced administration of antipsychotic medication during trial violated Riggins' rights under the Sixth and Fourteenth Amendments of the Federal Constitution.

We hold that it did.

The forceable administration of medication represents a substantial interference on a person's liberty.

In the case of antipsychotic drugs which are designed to alter the brain's chemical balance and which may have serious or even fatal side effects, the interference is particularly severe.

Thus, once Riggins moved to terminate administration of antipsychotic medication, Nevada became obligated to establish the need for Mellaril and the medical appropriateness of the drug.

The Trial Court, however, denied Riggins' motion to stop administration of Mellaril without making any determination of the need for the medication or any findings about alternatives to forcing antipsychotic medication on Riggins.

This error may well have impaired Riggins' trial rights.

The testimony of doctors who examined Riggins establishes that the dosage he received was within the toxic range and may have made him nervous, drowsy, or confused during the trial.

Such side effects may have impacted Riggins' demeanor but for jurors, the content of his trial testimony, his ability to follow the proceedings or his communication with his counsel.

Because the record offers no basis for saying that this strong possibility of trial prejudice was justified, we reverse the judgment bellow and remand the case for further proceedings not inconsistent with our opinion.

Justice Kennedy has filed an opinion concurring in the judgment of the Court; Justice Thomas has filed a dissenting opinion which Justice Scalia has joined in part.