Riggins v. Nevada
Encyclopedia
Riggins v. Nevada, is a U.S. Supreme Court
case in which the court decided whether a mentally ill
person can be forced to take
antipsychotic medication while they are on trial
to allow the state to make sure they remain competent during the trial
.
apartment of a man, Wade, who was later found stabbed to death. Approximately two days later, Riggins was arrested for the capital murder and robbery
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 milligrams 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 and requested that the Mellaril be discontinued until after the trial so that the jury
would see his mental state first hand rather than be given a false impression induced by the medication, which would deny him due process
. The court heard testimony
from three psychiatrists with differing opinions and then gave a one page decision denying Riggins' request but giving no rationale for the denial. Riggins testified on his own behalf during the trial, claiming that Wade was trying to kill him and that voices in his head told him that killing Wade was justified as self defense. The jury found Riggins guilty of murder and robbery with a deadly weapon, and sentenced him to death
.
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.
and Fourteenth Amendment
s. 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, by a seven person majority, that a person awaiting trial has a valid reason, protected under the due process
clause, to refuse antipsychotic drugs, see Washington v. Harper
, 494 U.S. 210 and Bell v. Wolfish
, 441 U.S. 520, 545. 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.
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
), the court did not say that involuntary medication is never appropriate to achieve the state's goal.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the court decided whether a mentally ill
Mental illness
A mental disorder or mental illness is a psychological or behavioral pattern generally associated with subjective distress or disability that occurs in an individual, and which is not a part of normal development or culture. Such a disorder may consist of a combination of affective, behavioural,...
person can be forced to take
Involuntary treatment
Involuntary treatment refers to medical treatment undertaken without a person's consent. In almost all circumstances, involuntary treatment refers to psychiatric treatment administered despite an individual's objections...
antipsychotic medication while they are on trial
Trial
A trial is, in the most general sense, a test, usually a test to see whether something does or does not meet a given standard.It may refer to:*Trial , the presentation of information in a formal setting, usually a court...
to allow the state to make sure they remain competent during the trial
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
.
Circumstances
David Riggins went to the NevadaNevada
Nevada is a state in the western, mountain west, and southwestern regions of the United States. With an area of and a population of about 2.7 million, it is the 7th-largest and 35th-most populous state. Over two-thirds of Nevada's people live in the Las Vegas metropolitan area, which contains its...
apartment of a man, Wade, who was later found stabbed to death. Approximately two days later, Riggins was arrested for the capital murder and robbery
Robbery
Robbery is the crime of taking or attempting to take something of value by force or threat of force or by putting the victim in fear. At common law, robbery is defined as taking the property of another, with the intent to permanently deprive the person of that property, by means of force or fear....
of Wade. After his arrest he complained of hearing voices
Hallucination
A hallucination, in the broadest sense of the word, is a perception in the absence of a stimulus. In a stricter sense, hallucinations are defined as perceptions in a conscious and awake state in the absence of external stimuli which have qualities of real perception, in that they are vivid,...
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 milligrams a day, considered a very high dose of that medication.
Riggins was evaluated and found competent to stand trial
Competency evaluation (law)
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process....
, with one of the three evaluating psychiatrists dissenting. Riggins stated he planned to present an insanity defense and requested that the Mellaril be discontinued until after the trial so that the jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
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
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
. The court heard testimony
Testimony
In law and in religion, testimony is a solemn attestation as to the truth of a matter. All testimonies should be well thought out and truthful. It was the custom in Ancient Rome for the men to place their right hand on a Bible when taking an oath...
from three psychiatrists with differing opinions and then gave a one page decision denying Riggins' request but giving no rationale for the denial. Riggins testified on his own behalf during the trial, claiming that Wade was trying to kill him and that voices in his head told him that killing Wade was justified as self defense. The jury found Riggins guilty of murder and robbery with a deadly weapon, and sentenced him to death
Capital punishment in the United States
Capital punishment in the United States, in practice, applies only for aggravated murder and more rarely for felony murder. Capital punishment was a penalty at common law, for many felonies, and was enforced in all of the American colonies prior to the Declaration of Independence...
.
Appeals
Riggins appealed to the Nevada Supreme CourtSupreme Court of Nevada
The Supreme Court of Nevada is the state supreme court of Nevada. It is the highest judicial body of the Nevada state government.There are seven Justices of the court, who are elected to six-year terms in officially nonpartisan elections. The Governor appoints Justices in the case of a vacancy...
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.
Decision
The Supreme Court reversed and remanded, holding that forced administration of antipsychotic medication during Riggins' trial violated his rights guaranteed under the SixthSixth Amendment to the United States Constitution
The Sixth Amendment to the United States Constitution is the part of the United States Bill of Rights which sets forth rights related to criminal prosecutions...
and Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
s. 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
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
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, by a seven person majority, that a person awaiting trial has a valid reason, protected under the due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
clause, to refuse antipsychotic drugs, see Washington v. Harper
Washington v. Harper
Washington v. Harper 494 U.S. 210 is a case in which an incarcerated inmate sued the state of Washington over the issue of involuntary medication, specifically antipsychotic medication.-Circumstances:...
, 494 U.S. 210 and Bell v. Wolfish
Bell v. Wolfish
Bell v. Wolfish, 441 U.S. 520 , is a case in which the United States Supreme Court found that it was not a violation of the Fourth Amendment to perform intrusive body searches on pre-trial detainees.-Significance:...
, 441 U.S. 520, 545. 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
Washington v. Harper
Washington v. Harper 494 U.S. 210 is a case in which an incarcerated inmate sued the state of Washington over the issue of involuntary medication, specifically antipsychotic medication.-Circumstances:...
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
Adverse drug reaction
An adverse drug reaction is an expression that describes harm associated with the use of given medications at a normal dosage. ADRs may occur following a single dose or prolonged administration of a drug or result from the combination of two or more drugs...
), the court did not say that involuntary medication is never appropriate to achieve the state's goal.
See also
- List of United States Supreme Court cases, volume 504
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
- Sell v. United StatesSell v. United StatesSell v. United States, is a landmark decision in which the United States Supreme Court imposed stringent limits on the right of a lower court to order the forcible administration of antipsychotic medication to a criminal defendant who had been determined to be incompetent to stand trial for the...
- Perry v. LouisianaPerry v. LouisianaPerry v. Louisiana is a case brought before the U.S. Supreme Court over the legality of the forcibly medicating a death row inmate with a mental disorder in order to render him competent to be executed.-Circumstances:...
- Ford v. WainwrightFord v. WainwrightFord v. Wainwright, ', was the case in which the United States Supreme Court upheld the common law rule that the insane cannot be executed; therefore the petitioner is entitled to a competency evaluation and to an evidentiary hearing in court on the question of his competency to be...
External links
- S Supreme Court Center> US Supreme Court Cases & Opinions> Volume 504 > Riggins v. Nevada 504 U.S. 12
- Riggins v. Nevada case transcript
- Riggins v. Nevada - Opinion
- Riggins v. Nevada, 504 U.S. 127, 2 (1992)
- Medicating Incompetent Defendants against Their Will to Restore Competency: Sell v. United States Changes Current Practice
- American Bar Association - Forced Medication of Legally Incompetent Prisoners: A Primer
- Summary New York State Defenders Association
- Oyez