Riggins v. Nevada
112 S. Ct. 1810, 1992 U.S. LEXIS 2701, 504 U.S. 127 (1992)
Rule of Law:
The State cannot force antipsychotic medication on a criminal defendant during trial, particularly when an insanity defense is asserted, unless a court first makes specific findings of overriding justification and medical appropriateness, having considered less intrusive alternatives.
Facts:
- During the early hours of November 20, 1987, Paul Wade was found dead in his Las Vegas apartment from multiple stab wounds.
- David Riggins was arrested for Wade's killing 45 hours later.
- A few days after being taken into custody, Riggins told Dr. R. Edward Quass, a psychiatrist, about hearing voices and having trouble sleeping, informing the doctor he had been successfully treated with Mellaril (an antipsychotic drug) in the past.
- Dr. Quass prescribed Mellaril, gradually increasing the dosage from 100 milligrams to 800 milligrams per day as Riggins continued to complain of voices and sleep problems.
- While Riggins was taking 450 milligrams of Mellaril daily, three court-appointed psychiatrists examined him; two concluded he was competent to stand trial, while one found him incompetent.
- Before his trial, the defense moved the District Court for an order suspending administration of Mellaril and Dilantin, arguing it infringed on Riggins' freedom, affected his demeanor, denied him due process, and prevented him from showing jurors his 'true mental state' for his insanity defense.
- At trial, Riggins presented an insanity defense, testifying that on the night of Wade’s death he used cocaine, fought with Wade, and heard voices telling him that killing Wade was justifiable.
- Riggins continued to receive 800 milligrams of Mellaril each day through the completion of his trial in November 1988.
Procedural Posture:
- David Riggins was arrested for the killing of Paul Wade.
- Riggins successfully moved for a determination of his competence to stand trial in the Clark County District Court (trial court).
- The Clark County District Court (trial court) determined Riggins was legally sane and competent to stand trial.
- Riggins' defense moved the Clark County District Court (trial court) for an order suspending administration of Mellaril and Dilantin until the end of his trial.
- The Clark County District Court (trial court) held an evidentiary hearing on Riggins' motion.
- The Clark County District Court (trial court) denied Riggins' motion to terminate medication with a one-page order that gave no indication of the court's rationale.
- A jury in the Clark County District Court (trial court) found Riggins guilty of murder with use of a deadly weapon and robbery with use of a deadly weapon, and sentenced him to death.
- Riggins, as appellant, appealed his convictions and death sentence to the Nevada Supreme Court, claiming, among other issues, that forced administration of Mellaril denied him a fair trial.
- The Nevada Supreme Court affirmed Riggins’ convictions and death sentence, holding that expert testimony was sufficient to inform the jury of the drug's effect and that denial of the motion to terminate medication was neither an abuse of discretion nor a violation of Riggins’ trial rights.
- Riggins, as petitioner, sought and was granted certiorari by the Supreme Court of the United States.
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Issue:
Does forcing a criminal defendant to take antipsychotic medication during trial, without a court finding of overriding justification and medical appropriateness after considering less intrusive alternatives, violate the defendant's Fourteenth Amendment due process rights to a fair trial, especially when the defendant raises an insanity defense?
Opinions:
Majority - Justice O’Connor
Yes, forcing a criminal defendant to take antipsychotic medication during trial, without sufficient court findings of overriding justification and medical appropriateness, violates the defendant's due process rights under the Fourteenth Amendment and potentially his Sixth Amendment rights to a fair trial. The Court drew upon its prior holding in Washington v. Harper, establishing that an individual has a protected liberty interest under the Fourteenth Amendment's Due Process Clause in avoiding the involuntary administration of antipsychotic drugs, viewing such administration as a "substantial interference with that person’s liberty." This protection extends at least as much to pretrial detainees as to convicted prisoners. Therefore, once Riggins moved to terminate medication, the State was obligated to demonstrate the medical appropriateness of Mellaril and an overriding justification for its forced administration. Such justification would include establishing that the medication was essential for Riggins’s or others' safety (considering less intrusive alternatives) or that the State could not obtain an adjudication of guilt or innocence by less intrusive means. The District Court failed to make any determination of the need for Mellaril or findings about reasonable alternatives, simply weighing potential prejudice against the risk of incompetence and failing to acknowledge Riggins’ liberty interest. The Court found a "strong possibility" that the forced medication impaired Riggins’ constitutionally protected trial rights by affecting his outward appearance, the content of his testimony, his ability to follow proceedings, or his communication with counsel, as suggested by medical testimony. The Court concluded that allowing expert testimony about the drug's effects on demeanor did not cure the potential prejudice to these fundamental trial rights, and absent findings of an essential state interest, the substantial probability of trial prejudice could not be justified.
Dissenting - Justice Thomas
No, even if Nevada improperly forced Riggins to take medication, he nonetheless had a fundamentally fair criminal trial, and the deprivation of a liberty interest in avoiding unwanted medication, without more, should not lead to the reversal of his conviction. Justice Thomas argued that the majority improperly conflated two distinct questions: whether Riggins had a full and fair trial and whether Nevada improperly forced him to take medication, with Riggins only seeking reversal of his conviction. He asserted that Riggins received a fair trial because expert testimony, including Riggins' own, was sufficient to inform the jury of Mellaril's potential effects on his demeanor and testimony. Furthermore, Riggins was found legally competent to stand trial while medicated, and there was no specific factual allegation that Mellaril actually diminished his ability to participate in his defense; in fact, some testimony suggested it enhanced his cognitive ability. Justice Thomas also contended that Riggins did not specifically argue for reversal based on a Harper-type liberty interest deprivation in the state courts, focusing instead on trial strategy, and thus the Court should not address this new claim. Even if a Harper violation occurred, he argued it was not a "trial error" or "structural defect" that would warrant reversal of a criminal conviction, but rather might merit civil remedies. He criticized the majority for adopting a standard of strict scrutiny and requiring consideration of "less intrusive alternatives," which he argued were explicitly rejected or not mandated by Harper for convicted prisoners, and which the majority wrongly applied to detainees without clear justification for a different standard.
Concurring - Justice Kennedy
Yes, a defendant medicated against his will in order to stand trial may challenge his conviction, as the State's interference with his behavior constitutes a serious threat to a fair trial, and the Due Process Clause generally prohibits such involuntary medication without an "extraordinary showing" by the State. Justice Kennedy fully agreed that review in the criminal proceeding is appropriate because state-commanded medication to alter a defendant's behavior is akin to manipulating material evidence, directly interfering with the trial's fairness. He acknowledged the State's legitimate interest in restoring competence to stand trial, but emphasized that when medication is specifically for competence to stand trial rather than merely safety, the State faces a higher burden. To justify involuntary medication, the State must make an "extraordinary showing" that there is no significant risk the medication will impair or alter in any material way the defendant’s capacity or willingness to react to testimony or assist counsel. Given the current medical understanding of antipsychotic drugs and their known side effects (e.g., parkinsonism, tremor, diminished facial expression, sedation, dull cognition), which can prejudice a defendant's demeanor and appearance, and hamper attorney-client communication and self-determination, Justice Kennedy expressed doubt that such a showing could be made in most cases. He concluded that if competence cannot be achieved without involuntary medication that substantially affects behavior and demeanor, then society must bear this cost (e.g., civil commitment) to preserve the integrity of the trial process.
Analysis:
This case significantly reinforces the due process rights of criminal defendants, particularly pretrial detainees, to freedom from involuntary antipsychotic medication during trial. It extends the liberty interest recognized in Washington v. Harper from the prison context to the trial setting, imposing stringent requirements on the State to justify such intervention. The ruling highlights the critical importance of a defendant's natural demeanor and cognitive abilities to a fair trial, especially when an insanity defense is mounted, and signals judicial skepticism toward state-imposed chemical alterations of a defendant for prosecutorial convenience. Future cases will likely scrutinize state justifications for involuntary medication more closely, requiring specific findings on medical necessity, safety, and the exploration of less intrusive alternatives before infringing on a defendant's fundamental liberty and trial rights.
