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211174P.pdf 08/25/2021 United States v. Johnathan Mitchell
U.S. Court of Appeals Case No: 21-1174
U.S. District Court for the Northern District of Iowa - Cedar Rapids
[PUBLISHED] [Kelly, Author, with Loken and Erickson, Circuit Judges]
Criminal case - Competency - Involuntary Medication. Given the purpose of
involuntary medication under Sell v. U.S., 539 U.S. 166 (2003) is to
ensure the defendant is competent enough to participate in trial, adopting
a rule that categorically prohibits the involuntary medication of a
defendant who had regained competency for some period of time, but is
unable to maintain it, would frustrate that purpose where an important
governmental interest is at stake; accordingly, the district court did not
err in concluding it had the authority to order defendant's involuntary
medication for the purpose of rendering and maintaining his competency for
trial; the district court's order is narrowly tailored to minimize the
intrusion on defendant's protected liberty interests while furthering the
government's interest in timely prosecution.