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4th Circuit Blocks Forced Medication of Schizophrenic Defendant

By William Peacock, Esq. on June 11, 2013 | Last updated on March 21, 2019

Frank Chatmon faces a life sentence if convicted of charges related to a massive drug-trafficking conspiracy. The biggest problem for the government, however, will be getting him to face those charges in court.

Before he could stand trial, his attorney noticed a deterioration in his mental state. Things got so bad that Chatmon’s attorney began to doubt that he had the capacity to understand the proceedings, and filed a motion seeking a formal competency evaluation.

The results certainly backed counsel's suspicions. Chatmon was diagnosed with paranoid schizophrenia. Some of his symptoms included a belief that a satellite was attached to his brain and that his thoughts were being controlled remotely. Further evaluation found paranoid ideation, auditory hallucinations, delusional beliefs, hostility, and tangential conversation.

In short: he was, without a doubt, incompetent. The second evaluation, done while Chatmon was being held in solitary confinement, also stated that antipsychotic medication might restore his competency. On the other hand, such drugs might also cause fatal cardiovascular side effects or tardive dyskinesia.

Chatmon declined the treatment, and at the same time, was transferred to an open population unit. While there, he showed great improvement in dealing with the staff, got along with his roommate, exercised regularly, and expressed his desire to take a GED class. Nonetheless, his competency was not reevaluated.

The government filed a motion seeking to forcibly medicate Chatmon, which the court granted after analyzing the request under the four-part test provided by Shell v. United States:

  1. Important government interest at stake;
  2. Involuntary medication will further that interest by likely rendering defendant competent;
  3. Involuntary medication must be necessary, and no less intrusive means are available to achieve "substantially the same results";
  4. Administration of drugs is medically appropriate and in the patient's best interests.

Chatmon contends that there is no important government interest here, as his alleged crime was not against a "person or property," as mentioned in Sell. The measure of whether an offense is serious enough to become an "important government interest" is the length of the sentence, not the type of crime. Chatmon faces a life sentence. Also, the Sell "person or property" language was provided as an example, not a rule.

The experts' evaluation stated that medication would likely restore competency.

But what about "less intrusive means"? The district court's analysis was perfunctory and consisted of a bare assertion -- basically that medication would work and nothing else would.

The Fourth Circuit reversed the order for forced medication, citing a few alternatives that should be explored and discussed by the court on the record, including the Sell suggestion of threatening contempt of court if medication is not taken and Chatmon's suggestions of group therapy and returning Chatmon to the open population unit (he returned to solitary confinement after the evaluation was completed).

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