Peo in Interest of Kreidler, 24CA1178

Richard Dana Kreidler was civilly committed to the Colorado Mental Health Hospital in Pueblo (CMHHIP) after being found permanently incompetent to proceed in a criminal case and having his charges dismissed.
Kreidler was diagnosed with schizoaffective disorder, bipolar type, with symptoms including delusions, significant mood shifts, and responses to internal stimuli.
He remained hospitalized due to being assessed as gravely disabled and a danger to others.
Kreidler consistently refused to take prescribed antipsychotic and mood-stabilizing medication, resulting in multiple involuntary treatment orders.
The People petitioned for continued involuntary administration of medication; after a hearing, the district court granted the petition, authorizing use of several medications.
Kreidler appealed, challenging the sufficiency of the evidence for involuntary medication, specifically under the standard from People v. Medina.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency under fourth Medina factor (override refusal to medicate)	Kreidler lacked a bona fide/legitimate reason to refuse; need was compelling	Kreidler asserted a legitimate interest in bodily autonomy and avoiding severe side effects	Court found Kreidler's treatment need sufficiently compelling to override refusal

People v. Medina, 705 P.2d 961 (Colo. 1985) (sets four-factor test for involuntary antipsychotic medication for civilly committed patients)
People v. Pflugbeil, 834 P.2d 843 (Colo. App. 1992) (psychiatrist testimony may meet clear and convincing evidence standard for involuntary medication)
People in Interest of A.J.L., 243 P.3d 244 (Colo. 2010) (appellate deference to factual findings if supported by the record)
Sell v. United States, 539 U.S. 166 (U.S. 2003) (tests for involuntary medication differ based on state vs. federal proceedings)