Woodland v. Angus

20 Citing cases

  1. U.S. v. Santonio

    Case No. 2:00-CR-90C (D. Utah May. 3, 2001)   Cited 2 times

    See Harper, 494 U.S. at 230; Riggins v. Nevada, 504 U.S. 127, 134 (1993); United States v. Brandon, 158 F.3d 947, 954 (6th Cir. 1998); see also Joanne R. Propst, "Restoring Competency: Does the state have the right to force anti-psychotic medications on the mentally ill pretrial-detainee?", 49 Drake L. Rev. 147, 162-63 (2000). The Tenth Circuit has described this Fifth Amendment right as the "freedom from physical and mental restraint of the kind potentially imposed by antipsychotic drugs." Bee, 744 F.2d at 1393; accord Woodland v. Graves, 820 F. Supp. 1497, 1504-05 (D.Utah 1993). Second, there is the First Amendment interest in free expression: the drugs may interfere with Mr. Santonio's ability to communicate ideas.

  2. State v. Garcia

    233 Conn. 44 (Conn. 1995)   Cited 51 times
    Rejecting claim that state common law provided defendant with β€œliberty interest broader or more absolute than arises as a matter of substantive due process under the federal constitution, in freedom from involuntary treatment to restore him to competency”

    We agree with the conclusion of the District of Columbia Court of Appeals that the state's interest in bringing a defendant to trial can be an "overriding justification" for involuntary medication under Riggins. Accord Woodland v. Angus, 820 F. Sup. 1497, 1511 (D.Utah 1993). Presumably, if the defendant was a present danger to himself or others, the state would make such a claim in its motion to medicate the defendant, because proof that the defendant is a danger to himself or others is sufficient to allow the state to pursue medically appropriate involuntary treatment of the defendant to alleviate that danger without consideration as to whether such medication is necessary to bring the defendant to trial.

  3. Jurasek v. Payne

    959 F. Supp. 1441 (D. Utah 1997)   Cited 1 times

    Litigation ensued, and after substantial proceedings and hearings the policy absent a requirement of dangerousness was held to be unconstitutional as applied to the pretrial detainee in that case. Woodland v. Angus, 820 F. Supp. 1497 (D.Ut. 1993). Whether the dangerousness requirement is mandatory as applied to incompetent, civilly committed and institutionalized patients was a matter of uncertainty during the pendency of that litigation, and has remained so even after the court's ruling in March 1993.

  4. U.S. v. Brandon

    158 F.3d 947 (6th Cir. 1998)   Cited 55 times
    Holding strict scrutiny applies because the defendant's right to be free from involuntary medication is a fundamental right

    To forcibly medicate Brandon, therefore, the government must satisfy strict-scrutiny review and demonstrate that its proposed approach is narrowly tailored to a compelling interest. See Greaves, 744 F.2d at 1395; Woodland v. Angus, 820 F. Supp. 1497, 1509 (D. Utah 1993)("the reduced standard of review applied by the Court in Harper is not appropriate in resolving th[e] case" where the government seeks to medicate an individual in order to render him competent to stand trial); see also Roe v. Wade, 410 U.S. at 154. We do not find the Supreme Court's opinion in Riggins determinative as to the appropriate standard of review to apply in this case.

  5. U.S. v. Weston

    Crim. No. 98-357 (EGS) (D.D.C. Nov. 22, 2004)

    It does not follow, however, that the government has an essential interest in prosecuting every alleged crime so as to justify involuntary medication in all cases. See Brandon, 158 F.3d at 961; Woodland v. Angus, 820 F.Supp. 1497, 1513 (1993) (stating that "the State's interest is not in trying plaintiff under any circumstances, but in trying plaintiff fairly and accurately"). Nor is the Court articulating a bright line test for determining which crimes trigger an essential interest in bringing a defendant to trial.

  6. U.S. v. Weston

    134 F. Supp. 2d 115 (D.D.C. 2001)   Cited 9 times
    Applying Harper and Riggins and concluding that, β€œ[a]lthough ... it is not certain that the medication will restore [the defendant's] competency, the [c]ourt credits the ... testimony of the mental health experts that this outcome is likely”

    It does not follow, however, that the government has an essential interest in prosecuting every alleged crime so as to justify involuntary medication in all cases. See Brandon, 158 F.3d at 961; Woodland v. Angus, 820 F. Supp. 1497, 1513 (1993) (stating that "the State's interest is not in trying plaintiff under any circumstances, but in trying plaintiff fairly and accurately"). Nor is the Court articulating a bright line test for determining which crimes trigger an essential interest in bringing a defendant to trial.

  7. Hightower by Dehler v. Olmstead

    959 F. Supp. 1549 (N.D. Ga. 1996)   Cited 12 times
    Holding thatRiggins had "rejected strict scrutiny as the appropriate standard to review state limitations on this type of liberty interest"

    Plaintiffs contend that the Harper and Riggins decisions reject deference to professional judgment. Plaintiffs also rely here on the decision in Woodland v. Angus, 820 F. Supp. 1497 (D.Utah 1993). However, Woodland is of little value in the present analysis for several reasons.

  8. In re Locks

    73 Cal.App.4th 1159 (Cal. Ct. App. 1999)

    ( People v. Drew (1978) 22 Cal.3d 333, 342.) In Woodland v. Angus (D. Utah 1993) 820 F. Supp. 1497, 1502, footnote 5, the court noted: ". . . [ΒΆ] Whether plaintiff has been found incompetent to stand trial is not dispositive of his medical competence.

  9. U.S. v. Gomes

    289 F.3d 71 (2d Cir. 2002)   Cited 14 times
    Finding felon in possession of a firearm, where defendant faced enhanced sentencing as an armed career criminal, to be a serious crime

    These concerns, which Gomes forcefully presents, were carefully articulated by Justice Kennedy in his concurrence in Riggins, 504 U.S. at 138-45, 112 S.Ct. 1810, and have been repeated in subsequent decisions. See Brandon, 158 F.3d at 961; United States v. Santonio, No. 2:00-CR-90C, 2001 WL 670932, at *3 (D.Utah May 3, 2001); Woodland v. Angus, 820 F.Supp. 1497, 1510 n. 15 (D.Utah 1993). Justice Kennedy was particularly troubled that the side effects of these drugs might, by making the defendant look bored or unfeeling, prejudice the jury and affect the outcome of the trial.

  10. Jurasek v. Utah State Hospital

    158 F.3d 506 (10th Cir. 1998)   Cited 105 times
    Holding that the "mere existence of a state regulatory scheme, however, does not mean the state has forged a liberty interest."

    The Hospital's actions are justified. Jurasek's reliance on Woodland v. Angus, 820 F. Supp. 1497 (D. Utah 1993), is misplaced. In Woodland, the court determined the Hospital's December 1991 policy was unconstitutional because it did "not require a finding that [the patient] is dangerous to himself, other, or property."