132085P.pdf   04/16/2014  United States  v.  James Curtis
   U.S. Court of Appeals Case No:  13-2085
   U.S. District Court for the Western District of Arkansas - Ft. Smith   
   [PUBLISHED] [Wollman, Author, with Bye and Melloy, Circuit Judges] 
   Criminal case - Criminal law. In a case involving involuntary medication 
   of the defendant to restore his competency to stand trial, the 
   government's evidence established the second factor identified in Sell v. 
   United States, 539 U.S. 106 (2003) -that administration of the drug 
   risperidone would significantly further the government's interest in 
   prosecuting the case - but the district court failed to make a specific 
   determination with respect to the fourth Sell factor - whether 
   administering the drug constituted a medically appropriate treatment for 
   defendant - and the matter must be remanded with directions to the 
   district court to determine whether the government has established by 
   clear and convincing evidence that involuntarily administering the 
   medication is medically appropriate.