State Of Washington, V Christopher Lyons
199 Wash. App. 235
Wash. Ct. App. U2017Background
- Lyons was charged with two counts of second-degree assault and repeatedly found incompetent to stand trial due to persistent delusions.
- Court ordered two 90-day competency restoration commitments; evaluators recommended involuntary antipsychotic medication to restore competency.
- The State sought a Sell hearing to authorize involuntary medication; Lyons received no advance notice of the State’s specific medical evidence and asked to continue to obtain a defense expert, which the trial court denied.
- Lyons identified a qualified expert and described the testimony (medication resistance of delusional disorder; likely multi-month timeline for restoration), but the trial court refused to allow the expert or continue the hearing.
- The trial court ordered involuntary medication; later evaluations still found Lyons incompetent and unlikely to regain competency, charges were dismissed and he was committed for civil evaluation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process entitles a defendant in a Sell hearing to present a defense expert | Lyons: Due process guarantees the right to present a complete defense, which can include a rebuttal expert to contest the State’s medical evidence | State: Trial court discretion; expert testimony may be excluded if irrelevant or inadmissible under ER 702 | Court: Yes—procedural due process can require allowing a defense expert at a Sell hearing when the expert is qualified and will offer admissible, relevant rebuttal evidence; reversal required |
| Whether trial court properly denied continuance to obtain/present an expert | Lyons: Denial prevented meaningful opportunity to be heard and to rebut State’s medical testimony | State: Court has discretion to manage continuances and may deny based on procedure, diligence, delay | Court: Trial court abused discretion here because Lyons demonstrated a qualified expert and specific rebuttal; but continuance decisions must balance diligence, prior delay, and orderly procedure in other cases |
Key Cases Cited
- Sell v. United States, 539 U.S. 166 (2003) (sets constitutional framework and factors for involuntary medication to restore competency)
- Washington v. Harper, 494 U.S. 210 (1990) (recognizes significant liberty interest against involuntary antipsychotic drugs)
- Riggins v. Nevada, 504 U.S. 127 (1992) (involuntary medication may interfere with privacy and fair trial rights)
- State v. Jones, 168 Wn.2d 713 (2010) (criminal defendant’s right to present evidence is limited by relevance and ER 702)
- In re Det. of Stout, 159 Wn.2d 357 (2007) (procedural due process requires meaningful opportunity to be heard)