U.S. v. WATSON, NO. 14-4388
Decided: July 17, 2015
The Fourth Circuit reversed the order of the district court and found that the government did not meet its burden of proving that involuntary medications were substantially likely to restore Defendant’s competency to stand trial.
In 2012, Defendant, John Watson (“Watson”), was arrested for firing a handgun at a Coast Guard helicopter. No one was injured or killed in the incident. After Watson’s arrest he was interviewed by a psychologists, who determined that he was “unable to participate meaningfully and effectively in his defense,” as a result of his many delusions. Watson was transferred to the Federal Medical Center (“FMC”) in Butner, North Carolina for further mental health evaluation. Six months later, the government submitted to the court a report by FMC psychiatrist, which recommended that Watson be forcibly medicated in order to render him competent to stand trial.
In 2014, the magistrate judge recommended that Watson be forcibly medicated in order to restore his competency. The district court then issued a brief order adopting the recommendations and findings of the magistrate judge and granting the government’s motion for involuntary medication.
Given the critical liberty interests at stake, the Court required the government to meet a heavy burden to justify forcible medication. The Court required that the government meet its burden by the “clear and convincing” standard. The Fourth Circuit applied a four-factor test to determine whether the burden had been met. First, the government had to show that important governmental interests are at stake and that special circumstances did not mitigate those interests. Second, the government had to show that involuntary medication significantly furthered the government’s interests, which requires proof that the medication is substantially likely to render the defendant competent to stand trial. Third, the involuntary medication must be necessary to further the government’s interests and less intrusive means must be unlikely to achieve substantially the same results. Finally, the Court must conclude that the administration of drugs is medically appropriate and in the patients best medical interests in light of his condition.
The Fourth Circuit found that the district court did not undertake the searching and individualized assessment of Watson’s likely susceptibility to forcible medication that is required by the four-factor test. The district court took the government at its word when it argued that the requirements of the test had been met, without considering whether the government had produced evidence “relating the proposed treatment plan to the individual defendant’s particular medical condition.”
Accordingly, the Court reversed the district court’s order.