Sell v. United States

Sell v. United States

When someone is mentally ill, medications may be able to help them balance out their mental state. Typically, people are allowed to choose whether or not to medicate. However, when someone accused of a crime refuses medication to treat a mental illness, the government has sometimes intervened to force them to take it. Sell v. United States is a case that helped the Supreme Court determine the limits of involuntary medication, and delineate for lower courts when involuntary medicating was appropriate for criminal defendants.

Sell's Case

Charles Sell worked as a dentist in the 1980s and 1990s. Early in his dental career, he talked to his doctor and said something the doctor found indicative of mental illness: namely, that the fillings he was putting into patients were “contaminated by communists.” Concerned, the doctor ordered him to a mental hospital and he was given medication to control the symptoms of schizophrenia. After his hospitalization, he resumed his dental practice, but continued to have difficulties with mental illness, including incidents in which he told police a leopard was getting on a city bus and several in which he thought people in his community were out to kill him.

In 1997, Sell was accused of Medicare fraud, after he attempted to gain payment from the Medicare system for procedures which had not been performed. At his initial hearing, he was judged to be competent, but the person performing the competency examination noted his history of mental illness and the possibility that these issues could arise again. Subsequently, Sell's behavior became increasingly bizarre. A second evaluation showed him not to be mentally competent.

The hospital said that Sell should have his antipsychotic medications administered again, to prevent him from becoming dangerous to himself or others. Sell did not wish to take the medication and sued. The magistrate at the trial ordered the medication on the grounds that Sell was dangerous and that he could be restored to competency through medication.

The Appeals

At trial, the district court ruled in Sell v. United States that the hospital had not been able to prove that Sell actually presented any kind of danger to himself or others. After all, the crime he had been accused of was not a crime that was actually dangerous to life or health. However, the argument that medication could restore his competency was accepted. The circuit court affirmed the district court's judgment.

Supreme Court Ruling

The Supreme Court found in Sell v. United States that the district and circuit courts had erred in ordering Sell to be medicated. While the lower courts had found that Sell's competence could be restored with the medication, the Supreme Court ruled that the physician's competency evaluation focused exclusively on whether Sell was dangerous or not, and didn't really address competency.

The court also ruled that restoring competency alone was not a good enough reason to involuntarily medicate a psychiatric patient except in very rare instances—requiring the government to prove that such medication would not have significant side effects and that medicating the defendant would serve a compelling governmental interest.