Sell v. United States

Sell v. United States
Supreme Court of the United States
Argued March 3, 2003 Decided June 16, 2003
Full case name	Charles Thomas Sell, Petitioner v. United States
Citations	539 U.S. 166 (more) 123 S. Ct. 2174; 156 L. Ed. 2d 197; 2003 U.S. LEXIS 4594; 71 U.S.L.W. 4456; 188 A.L.R. Fed. 679; 2003 Cal. Daily Op. Service 5131; 2003 Daily Journal DAR 6512; 16 Fla. L. Weekly Fed. S 359
Case history
Prior	Order granting permission to administer drug, United States v. Sell, No. 4:98-cr-177 (E.D. Mo. Aug. 9, 2000); affirmed, 2001 WL 35838455, 2001 U.S. Dist. LEXIS 26009 (E.D. Mo. Apr. 4, 2001); affirmed, 282 F.3d 560 (8th Cir. 2002); cert. granted, 537 U.S. 999 (2002).
Subsequent	Remanded to district court, 343 F.3d 950 (8th Cir. 2003).
Holding
Drugs to make defendant competent to stand trial may be administered involuntarily under very limited circumstances.
Court membership
Chief Justice William Rehnquist Associate Justices John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy David Souter · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer
Case opinions
Majority	Breyer, joined by Rehnquist, Stevens, Kennedy, Souter, Ginsburg
Dissent	Scalia, joined by O'Connor, Thomas
Laws applied
U.S. Const. amend. VI, XIV

Sell v. United States, 539 U.S. 166 (2003), is a decision in which the United States Supreme Court imposed stringent limits on the right of a lower court to order the forcible administration of antipsychotic medication to a criminal defendant who had been determined to be incompetent to stand trial for the sole purpose of making them competent and able to be tried. Specifically, the court held that lower courts could do so only under limited circumstances in which specified criteria had been met. In the case of Charles Sell, since the lower court had failed to determine that all the appropriate criteria for court-ordered forcible treatment had been met, the order to forcibly medicate the defendant was reversed.^[1]

Previously, in Washington v. Harper,^[2] the Supreme Court made clear that the forced medication of inmates with mental disorders could be ordered only when the inmate was a danger to themselves or others and when the medication is in the inmate's own best interests. In addition, courts must first consider "alternative, less intrusive means" before resorting to the involuntary administration of psychotropic medication.^[2][1]

Using the framework set forth in Riggins v. Nevada,^[3] the Court emphasized that an individual has a constitutionally protected "interest in avoiding involuntary administration of antipsychotic drugs" and this interest is one that only an "essential" or "overriding" state interest might overcome.^[1]