U.S. v. Fieste

In prosecution on charges of threatening to assault and murder two federal judges, three former U.S. presidents and current President, Dist. Ct. did not violate defendant’s due process rights by granting state’s motion to involuntarily medicate defendant to render her competent to stand trial. Record showed that defendant had struggled with mental illness for over 30 years and was determined to be not competent to stand trial with diagnosis of delusional disorder. During hearing on State’s motion, all three medical experts opined that defendant had substantial probability of obtaining competency by taking antipsychotic drug Prolixtin over period of time, and that defendant was unlikely to obtain competency without undergoing said treatment, which defendant was currently refusing to do. Under Sell, 539 U.S. 166, Dist. Ct. could properly impose involuntary medication order, where Dist. Ct. could properly find that: (1) government had important interest in bringing defendant’s charges to trial given serious nature of said charges, even though time for treatment plan, as well as time defendant had already spent in pre-trial custody would be longer than contemplated sentencing range for defendant; and (2) proposed treatment plan had substantial likelihood to render defendant competent and that any side effects of treatment plan were unlikely to interfere with defendant’s ability to participate in trial. However, remand was required, where Dist. Ct. had failed to include dosage range of proposed drug in its order.