U.S. v. Debenedetto

In proceeding to determine defendant’s competency to assist counsel in defense of transmitting interstate threats charge, Dist. Ct. erred in entering order under 18 USC section 4241(d)(2)(A) that defendant should be committing for medical treatment, including involuntary medication, for purposes of making defendant able to attain capacity to permit criminal proceedings to go forward. Dist. Ct. failed to provide required explicit findings that established: (1) importance of govt. interest in subjecting defendant to course of medical treatment without making preliminary finding regarding any potential sentence; (2) likelihood that proposed course of treatment would render defendant competent to stand trial and would subject him to deleterious side effects; (3) lack of existence of less intrusive alternatives to proposed involuntary drug treatment; and (4) appropriateness of proposed course of treatment in view of defendant’s diagnosis and personal medical history.