''Riggins v. Nevada'', 504 U.S. 127 (1992), is a

U.S. Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...

case in which the court decided whether a

mentally ill A mental disorder, also referred to as a mental illness, a mental health condition, or a psychiatric disability, is a behavioral or mental pattern that causes significant distress or impairment of personal functioning. A mental disorder is ...

person can be forced to take antipsychotic medication while they are on

trial In law, a trial is a coming together of parties to a dispute, to present information (in the form of evidence) in a tribunal, a formal setting with the authority to adjudicate claims or disputes. One form of tribunal is a court. The tribunal, w ...

to allow the state to make sure they remain competent during the trial..

Background

During the early hours of November 20, 1987, David Riggins went to the

Nevada Nevada ( ; ) is a landlocked state in the Western United States. It borders Oregon to the northwest, Idaho to the northeast, California to the west, Arizona to the southeast, and Utah to the east. Nevada is the seventh-most extensive, th ...

apartment of Paul Wade, who was later found stabbed to death. Approximately two days later, Riggins was arrested for the

capital murder Capital murder refers to a category of murder in some parts of the US for which the perpetrator is eligible for the death penalty. In its original sense, capital murder was a statutory offence of aggravated murder in Great Britain, Northern Irela ...

and

robbery Robbery is the crime of taking or attempting to take anything of value by force, threat of force, or use of fear. According to common law, robbery is defined as taking the property of another, with the intent to permanently deprive the person o ...

of Wade. After his arrest he complained of hearing voices and sleeplessness, telling the jail psychiatrist that he had taken Mellaril in the past. The psychiatrist prescribed him increasing doses of Mellaril at Riggins' request, until Riggins was taking 800

milligram The kilogram (also spelled kilogramme) is the base unit of mass in the International System of Units (SI), equal to one thousand grams. It has the unit symbol kg. The word "kilogram" is formed from the combination of the metric prefix kilo- (m ...

s a day, considered a very high dose of that medication. Riggins was evaluated and found competent to stand trial, with one of the three evaluating psychiatrists dissenting. Riggins stated he planned to present an

insanity defense The insanity defense, also known as the mental disorder defense, is an affirmative Defense (legal), defense by excuse in a criminal case, arguing that the defendant is not responsible for their actions due to a mental illness, psychiatric disease ...

and requested that the Mellaril be discontinued until after the trial so that the

jury A jury is a sworn body of people (jurors) convened to hear evidence, make Question of fact, findings of fact, and render an impartiality, impartial verdict officially submitted to them by a court, or to set a sentence (law), penalty or Judgmen ...

would see his mental state first hand rather than be given a false impression induced by the medication, which would deny him

due process Due process of law is application by the state of all legal rules and principles pertaining to a case so all legal rights that are owed to a person are respected. Due process balances the power of law of the land and protects the individual p ...

. The court heard

testimony Testimony is a solemn attestation as to the truth of a matter. Etymology The words "testimony" and "testify" both derive from the Latin word ''testis'', referring to the notion of a disinterested third-party witness. Law In the law, testimon ...

from three psychiatrists with differing opinions and then gave a one-page decision denying Riggins' request but giving no rationale for the denial. At trial, Riggins presented an insanity defense and testified on his own behalf. He indicated that, on the night of Wade's death, he used cocaine before going to Wade's apartment. Riggins admitted fighting with Wade, but claimed that Wade was trying to kill him and that voices in his head said that killing Wade would be justifiable homicide. A jury found Riggins guilty of murder with use of a deadly weapon and robbery with use of a deadly weapon. After a penalty hearing, the same jury sentenced him to

death Death is the end of life; the irreversible cessation of all biological functions that sustain a living organism. Death eventually and inevitably occurs in all organisms. The remains of a former organism normally begin to decompose sh ...

Appeals

Riggins appealed to the Nevada Supreme Court on the grounds that forced administration of Mellaril denied him the ability to assist in his own defense and gave a false impression of his attitude, appearance, and demeanor at trial. Riggins claimed that the forced medication was not justified, as the State had not demonstrated a need to administer Mellaril nor did it explore less restrictive alternatives to giving him 800 milligrams of the drug each day. However, the Nevada Supreme Court affirmed Riggins' convictions and death sentence. Riggins then petitioned the U.S. Supreme Court.

Opinion of the Court

The Supreme Court reversed and remanded, holding that forced administration of antipsychotic medication during Riggins' trial violated his rights guaranteed under the Sixth and Fourteenth Amendments. A seven-member majority held that the state did not show that antipsychotic medication was medically appropriate and did not demonstrate that it considered less intrusive means in obtaining its goal of trying Riggins. The Court stated that Riggins' Eighth Amendment argument that the forcible administration of antipsychotic medication denied him the chance to show the jury his true mental state at the sentencing hearing was not raised in the petition for certiorari and therefore was not addressed by the court. The Court held that a person awaiting trial has a valid reason, protected under the

clause, to refuse antipsychotic drugs, referencing '' Washington v. Harper'' (1990) and '' Bell v. Wolfish'' (1979). Therefore, once Riggins' requested termination of the medication, the State was obligated to establish both the need for the antipsychotic drug and its medical appropriateness for Riggins' safety and that of others as the less restrictive alternative available. If the state had done this, due process would have been satisfied. The State might have been able to justify the treatment, if medically appropriate, if it set forth that the adjudication of guilt or innocence could not be established by using less intrusive means. Since the trial court did not do this and allowed the drug's administration to continue without making any of the determinations stated above, it is very likely that this error violated Riggins' trial rights established by the Constitution. However, this is only speculative as there is no way to know what the outcome would have been if the proper course had been followed.

Significance

This decision highlighted two factors not previously emphasized in cases involving involuntary medication. First, the involuntary treatment must be the least intrusive treatment for restoration of competence. Second, the proposed treatment must be medically appropriate for the individual's safety as well as that of others. In '' Washington v. Harper'', the individual protesting the involuntary medication was already incarcerated. The Court suggested in this case that a competent person has the right to refuse if the medication is administered for other than treatment reasons to a person not dangerous or extremely ill, but it accepted the institution's procedures for making such treatment decisions. However, Riggins was not convicted at the time he was involuntarily medicated. In ''Riggins v. Nevada'', the Court said that not only had the medication to be a medically appropriate means of attaining an important state objective such as competency, but the medication must be the least intrusive means of attaining the objective. However, although the treatment must be the least intrusive (for example, to allow the individual to retain a clear head to consult with his attorney as well as to avoid medication

side effects In medicine, a side effect is an effect of the use of a medicinal drug or other treatment, usually adverse but sometimes beneficial, that is unintended. Herbal and traditional medicines also have side effects. A drug or procedure usually used ...

), the court did not say that involuntary medication is never appropriate to achieve the state's goal.

Footnotes

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