Why is the case important?
An individual had a history of mental illness, but refused to take antipsychotic medicine while confined to a state treatment facility.
Facts of the case
In 1997, the Federal Government charged Charles Sell with submitting fictitious insurance claims for payment. Although Sell has a long history of mental illness and was initially found competent to stand trial for fraud and attempted murder, a Federal Magistrate Judge ordered his hospitalization to determine whether he would attain the capacity to allow his trial to proceed. Subsequently, the Magistrate authorized forced administration of antipsychotic drugs. In affirming, the District Court concluded that medication was the only viable hope of rendering Sell competent to stand trial and was necessary to serve the Federal Government’s interest in obtaining an adjudication of his guilt or innocence. The Court of Appeals affirmed. On the fraud charges, the appellate court found that the Federal Government had an essential interest in bringing Sell to trial, that the treatment was medically appropriate, and that the medical evidence indicated that Sell would fairly be able to participate in his trial.
Whether the Constitution permits the Government to administer antipsychotic drugs involuntarily to a mentally ill criminal defendant–in order to render that defendant competent to stand trial for serious, but nonviolent, crimes? Or, in other words does forced administration of antipsychotic drugs to render Sell competent to stand trial unconstitutionally deprive him of his ‘liberty’ to reject medical treatment?
“Yes, the Constitution allows the Government to administer those drugs, even against the defendant’s will, in limited circumstances.
Two prior precedents, Washington v. Harper and Riggins v. Nevada set forth the framework for determining the legal answer. In Harper, this Court recognized that an individual has a ‘significant’ constitutionally protected ‘liberty interest’ in ‘avoiding the unwanted administration of antipsychotic drugs.’ The Court found that the State’s interest in administering medication was ‘legitimate’ and ‘important,’
The United States Supreme Court assumed that Sell was not dangerous. Based on that hypothetical assumption, the United States Supreme Court found that the appellate court was wrong to approve forced medication solely to render Sell competent to stand trial. The experts focused mainly on the dangerousness issue to the exclusion of other important issues such as trial-related side effects and risks that could have helped determine whether forced medication was warranted on trial competence grounds alone. As a result, there was not enough information to know whether the side effects of the antipsychotic medication were likely to undermine the fairness of the trial in Sell’s case.
- Case Brief: 2003
- Petitioner: Sell
- Respondent: United States
- Decided by: Rehnquist Court
Citation: 539 US 166 (2003)
Argued: Mar 3, 2003
Decided: Jun 16, 2003