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Name: People v. Christiana
Case #: E048681
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 12/10/2010
Summary

An order authorizing a hospital to involuntarily administer antipsychotic medication to a defendant found incompetent to stand trial and committed for treatment must be predicated, in part, on identification of the specific medication. Under Penal Code section 1370, the state may authorize involuntary medication for treatment of a defendant who has been found incompetent to stand trial and has been committed for treatment. Any order must be supported by substantial evidence of the necessity, with focus on the following four factors: (1) whether important governmental interests were at stake, namely, was defendant charged with a serious crime, in light of the individual case; (2) whether there was substantial evidence that involuntarily medicating defendant would significantly further the concomitant governmental interests of timely prosecution and a fair trial; (3) whether there was substantial evidence that involuntarily medicating defendant was necessary to further those governmental interests, or whether are there less intrusive methods likely to achieve the required result; and (4) whether there was substantial evidence that administering antipsychotic medication was in the defendant’s best medical interest in light of his medical condition. Here, because the court was not provided with the specific medication and the maximum dosages to be administered, there was insufficient evidence to support the trial court’s order to involuntarily medicate appellant, and the order was reversed.