Having been left to fend for themselves as to this element of the analysis, the federal courts have split on the question whether "rational basis" or "strict scrutiny" review should apply to the task. Compare United States v. Brandon, 158 F.3d 947, 956-58 (6th Cir. 1998) (holding strict scrutiny applies because the defendant's right to be free from involuntary medication is a fundamental right), and Woodland v. Angus, 820 F. Supp. 1497, 1509-10 (D. Utah 1993) (same), with Hightower ex rel. Diehler v. Olmstead, 959 F. Supp. 1549, 1561 (N.D. Ga. 1996) (holding thatRiggins had "rejected strict scrutiny as the appropriate standard to review state limitations on this type of liberty interest"),and Jurasek v. Payne, 959 F. Supp. 1441, 1454 (D. Utah 1997) ("This court adopts the 'reasonably related' test rather than the 'compelling necessity' or 'strict scrutiny' tests . . . as the proper standard of review applicable to the policies and regulations . . . concerning involuntary medication of patients. . . .").