United States v. Charters
863 F.2d 302
Brief Filed: 6/88
Court: United States Court of Appeal for the Fourth Circuit
Year of Decision: 1988
Read the full-text amicus brief (PDF, 510KB)
Whether a hospitalized patient has a federal constitutional right to refuse antipsychotic drugs unless the patient has been found incompetent to make treatment decisions or is imminently dangerous to self or others
Medication (Right to Refuse)
Charters was indicted for making threats against the President. Finding Charters incompetent to stand trial, the district court ordered him confined to a federal correctional institution. On the government's motion, the court entered an order permitting involuntary medication with antipsychotic drugs, but stayed the order pending an appeal to the U.S. Court of Appeals for the Fourth Circuit. The Fourth Circuit reversed and remanded, holding that government interests did not justify involuntary medication and, to determine competence to make treatment decisions, the court must evaluate whether the defendant followed a rational process in making the decision and could offer rational reasons for the decision. The Fourth Circuit further held that if the defendant was incompetent to make treatment decisions, the court should first look for clear and convincing evidence of what the incompetent person would have decided if he had been competent and then, if that evidence was unavailable, the court should apply a best interests analysis.
APA's amicus brief argued that: (1) antipsychotic drugs are highly beneficial for many patients, but they also cause substantial side effects that implicate basic principles of individual autonomy and dignity; (2) a hospitalized patient has a federal constitutional right to refuse antipsychotic drugs unless the patient has been found incompetent to make treatment decisions or is imminently dangerous to self or others; and (3) judicial determinations of competency and substituted judgment are constitutionally required to protect an individual's right to refuse antipsychotic drugs.
The Fourth Circuit, en banc, held that the appropriate medical personnel could make a decision to implement involuntary forced medication, but that decision should be reviewable by a court.