Golden Gate University Law Review


In United States v. Ruiz-Gaxiola, the United States Court of Appeals for the Ninth Circuit held that the government could not medicate a defendant involuntarily for the sole purpose of rendering the defendant competent to stand trial. The court relied on the Sell test in making its determination. In Sell v. United States, the United States Supreme Court established a four-pronged test for determining whether a court should grant a request to medicate a defendant involuntarily. A court may not grant such a request unless the government shows that (1) an important government interest is at stake in prosecuting the defendant to be medicated, (2) medicating the defendant involuntarily will significantly further the important government interest, (3) medicating the defendant involuntarily is necessary to further the important government interest, and (4) the involuntary medication of the defendant is medically appropriate. The Ninth Circuit held that because the government failed to establish the facts necessary to satisfy all four prongs of the Sell test by clear and convincing evidence, the district court erred in authorizing the involuntary medication of the defendant.