Sell v. United States Case Brief

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.

Question

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?

Answer

“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,’

  • and it held that ‘the Due Process Clause permits the State to treat a prison inmate who has a serious mental illness with antipsychotic drugs against his will, if the inmate is dangerous to himself or others and the treatment is in the inmate’s medical interest.’ The Court concluded that, in the circumstances, the state law authorizing involuntary treatment amounted to a constitutionally permissible ‘accommodation between an inmate’s liberty interest in avoiding the forced administration of antipsychotic drugs and the State’s interests in providing appropriate medical treatment to reduce the danger that an inmate suffering from a serious mental disorder represents to himself or others.’ “

    Conclusion

    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