Supreme Court of the United States
Riggins v. Nevada
May 18, 1992504 U.S. 127
Summary
The Court held that Nevada violated Riggins' rights by continuing involuntary antipsychotic medication during his criminal trial without findings establishing its necessity or considering reasonable alternatives. The resulting substantial probability of trial prejudice warranted reversal without proof of precisely how the medication changed the proceedings; expert testimony about its effects on demeanor did not cure the risks to testimony, comprehension, and communication with counsel. Justice O'Connor wrote for six Justices. Justice Kennedy concurred in the judgment, arguing that medication to establish trial competence should require an extraordinary showing that it would not materially impair the defendant's participation or presentation. Justice Thomas dissented, joined by Justice Scalia except as to Part II–A, maintaining that Riggins received a fair trial and that an infringement of his liberty interest alone did not justify reversing his conviction.
Holding
- Justification required for involuntary antipsychotic medication during a criminal trial.. Once Riggins requested termination of antipsychotic medication, the State had to establish its need and medical appropriateness. Continuing medication without findings addressing necessity, reasonable alternatives, or overriding concerns violated his protected liberty interest.
- Whether the risk of trial prejudice justified reversal without a showing of actual prejudice.. The substantial probability that unjustified forced medication impaired Riggins' defense warranted reversal without requiring him to demonstrate exactly how an unmedicated trial would have differed. Expert testimony about demeanor did not cure the remaining risks.
Docket 90-8466
Cited authorities
- CA10
- Nev. Rev. Stat. § 178.400
- 15 Am. J. Crim. L. 1
- Nev. Rev. Stat. § 178.400
- 28 U.S.C. § 1257
- 42 U.S.C. § 1983