Peo in Interest of Zambrano, 25CA1120

Joshua D. Zambrano was committed to the Colorado Mental Health Hospital after being found incompetent to proceed in a criminal matter.
He was diagnosed with schizophrenia, exhibiting symptoms like delusions, paranoia, impulsivity, and assaultive behavior, leading to emergency medication administration.
The district court initially authorized involuntary administration of antipsychotic and mood-stabilizing drugs, which was previously upheld on appeal.
When Zambrano's symptoms persisted, the People petitioned to modify his medication, seeking to continue a monthly antipsychotic injection (UZEDY) and add daily oral Risperdal as needed.
Zambrano opposed medication on grounds of religious conviction, and complaints about side effects; the court found his concerns bona fide but outweighed by the state’s interest in safety and treatment.
The trial court authorized continued involuntary medication, finding the People met all requirements under the key legal test.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether involuntary medication is justified under the Medina test	State argued medication is necessary to prevent harm and deterioration, with no less intrusive alternatives, and Zambrano cannot competently refuse	Zambrano contested the necessity, citing religious objection and side effects, arguing these should outweigh State's interests	Court found Zambrano's interests bona fide but outweighed by State’s need to treat and maintain institutional safety

People v. Medina, 705 P.2d 961 (Colo. 1985) (sets four-factor test for involuntary medication orders outside of competency restoration)
Sell v. United States, 539 U.S. 166 (2003) (establishes legal standard for involuntary medication in competency restoration, distinguished here)