Facts
- David Riggins was charged with murder and robbery after a victim was found stabbed to death in Las Vegas.
- While detained pretrial, Riggins reported hearing voices and insomnia; a jail psychiatrist prescribed the antipsychotic drug Mellaril and increased the dosage over time to a very high level.
- Riggins sought a competency determination; psychiatrists disagreed, but the trial court found him competent and sane for trial purposes.
- Anticipating an insanity defense, Riggins moved to suspend Mellaril (and another medication) until after trial, arguing forced medication infringed bodily autonomy, altered demeanor and mental functioning, and prevented the jury from observing his “true” mental condition.
- At a hearing, testimony conflicted on whether stopping Mellaril would affect behavior and competence; the psychiatrist warned abrupt withdrawal could return psychosis and risk incompetence.
- The trial court denied the motion in a brief order without explaining its rationale or making findings; Riggins remained medicated throughout trial.
- Riggins testified and presented an insanity defense; the jury convicted and imposed a death sentence.
- The Nevada Supreme Court affirmed, reasoning Riggins had not shown prejudice and experts could explain medication effects to the jury.
Issues
- Whether forcibly administering antipsychotic medication to a defendant during trial over his objection violates the Fourteenth Amendment Due Process Clause.
- Whether such forced medication, given its potential effects on demeanor, comprehension, and testimony, violates Sixth Amendment fair-trial rights.
- What findings the State and trial court must make before continuing antipsychotic medication over a defendant’s objection during trial.
Decision
- The U.S. Supreme Court reversed the conviction and remanded.
- The Court held that continuing antipsychotic medication during trial over Riggins’s objection violated due process and implicated Sixth Amendment trial rights because the State did not justify the medication with required findings.
- Once Riggins objected, the State was required to prove both the need for continued medication and its medical appropriateness, including consideration of less intrusive alternatives.
- The trial court erred by permitting the regimen to continue without determining necessity or making findings about alternatives; a conclusory order was insufficient.
- The Court rejected the state court’s view that expert testimony at trial could substitute for prior, on-the-record findings addressing necessity and alternatives.
Legal Principles
- A pretrial detainee has a constitutionally protected liberty interest in avoiding involuntary administration of antipsychotic drugs under the Due Process Clause.
- After a defendant objects to antipsychotic medication, the State bears the burden to show medical appropriateness and necessity, with consideration of less intrusive alternatives.
- Forced medication may be permissible if medically appropriate and essential to the defendant’s safety or others’ safety, or if necessary to obtain a fair adjudication when less intrusive means will not suffice.
- Trial courts must make explicit findings supporting forced medication; an unexplained order does not satisfy due process.
- Because antipsychotic drugs can affect demeanor, communication with counsel, comprehension, and the presentation of mental-state defenses, forced medication can impair Sixth Amendment fair-trial rights.
Conclusion
The Court set aside the conviction because the State continued antipsychotic medication during trial without proving necessity and medical appropriateness or showing that less intrusive alternatives would not protect safety or permit a fair trial, and without trial-court findings addressing the medication’s impact on trial fairness.