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Name: People v. Coleman
Case #: A133226
Court: US Court of Appeals
District 1 DCA
Division: 3
Opinion Date: 08/01/2012

Substantial evidence supported the trial court’s order authorizing the defendant’s involuntary medication for purposes of restoring him to competency to stand trial. While the defendant was pending felony sex charges, he was found incompetent to stand trial pursuant to Penal Code section 1368. The court authorized the involuntary administration of antipsychotic medications and he was restored to competence. In a letter, the hospital requested authorization to involuntarily medicate the defendant again because he was refusing to take the medication that had restored him to competence and there was significant worsening of his symptoms of mental illness. Soon afterwards, the defendant was again found to be incompetent and the court issued an order authorizing involuntary administration of antipsychotic medications. On appeal, the defendant challenged the sufficiency of the evidence to support the trial court’s involuntary medication order. The Court of Appeal affirmed. The defendant’s treating physician indicated that without medication the defendant had delusions about a video alibi that did not exist. It was the doctor’s opinion there was a “significant chance” that competence would be restored with the use of medication. There was no meaningful difference between the doctor’s terms and the constitutional and statutory standard. Psychologists and psychiatrists uniformly agreed that medication was medically appropriate for the treatment of the defendant’s mental illness. The proposed medications were identified and had previously been administered to the defendant to successfully restore his competence. The prior dosages were contained in reports submitted by the hospital and the defendant had not suffered from any severe side effects. As such, there was substantial likelihood that competence would be restored with medication and that the medication was medically appropriate.

The court order was not fatally deficient even though it did not include limitations on the medications, maximum dosages, or the duration of treatment. The defendant argued that the court’s order, which authorized the involuntary administration of antipsychotic medications to the defendant “as prescribed by his treating psychiatrist,” was fatally nonspecific. The order complied with Penal Code section 1370, subdivision (a)(2)(B)(ii), which directs the trial court to authorize involuntary administration of antipsychotic medication when and as prescribed by the defendant’s treating physician. However, the Ninth Circuit has held that an order authorizing involuntary medication for the purpose of restoring the defendant to competence must provide some limitations on the medications that may be administered, the maximum dosages, and the duration of treatment. (United States v. Hernandez-Vasquez (9th Cir. 2008) 513 F.3d 908, 916-917.) Adherence to the standards stated in Hernandez-Vasquez was not necessary to ensure protection of the defendant’s liberty interest in avoiding the unwanted administration of antipsychotic drugs. Substantial evidence supported the finding that the course of treatment detailed in the record was medically appropriate for the defendant. Implicit in the court’s order was that the authorization of involuntary medication was to be consistent with the defendant’s well-documented prior treatment plan. It is unnecessary for California courts to specify the duration of the involuntary medication because section 1370, subdivision (b)(1) requires periodic judicial review. The medical director must make a written report to the court at 90 days initially and then at six-month intervals until the defendant regains competence.