State v. Seekins
299 Conn. 141
Conn.2010Background
- Seekins, incompetent to stand trial, was charged with multiple drug offenses including manufacturing and intent to sell marijuana.
- Court found involuntary medication could restore competency; ordered Whiting to administer treatment.
- Guardian ad litem appointed to represent Seekins’ health care interests under § 54-56d(k)(3)(A).
- Treatment plan proposed Risperdal, lithium, with Haldol as an alternative; close medical monitoring planned.
- Defendant appealed, challenging only the trial court’s conclusion that the crimes were sufficiently serious to override self-determination.
- Record reflects extensive prior history of competency restoration efforts and the state’s interest in bringing Seekins to trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the charges are serious enough to justify involuntary medication | State contends charges are serious, warranting trial, given quantity of marijuana and multi-offense nature | Seekins argues nonviolent marijuana offenses are not serious enough to override liberty interests | Yes; charges deemed serious, supporting state's override of self-determination |
Key Cases Cited
- Sell v. United States, 539 U.S. 166 (2003) (four-part Sell framework for involuntary medication)
- United States v. Evans, 404 F.3d 227 (4th Cir. 2005) (serious-crime inquiry and guideline-based analysis context)
- United States v. Green, 532 F.3d 538 (6th Cir. 2008) (seriousness of crime includes maximum penalty consideration)
- United States v. Hernandez-Vasquez, 513 F.3d 908 (9th Cir. 2008) (discussion of seriousness and nonviolent offenses under Sell)
- United States v. Gomes, 387 F.3d 157 (2d Cir. 2004) (integration of seriousness with potential consequences)
- Duncan v. Louisiana, 391 U.S. 145 (1968) (relevance of penalty in determining seriousness of a crime)
- State v. Jacobs, 265 Conn. 396 (2003) (recognition of Sell standard post-Sell interpretation in Connecticut)
- State v. Padua, 273 Conn. 138 (2005) (legislative view on marijuana as a dangerous substance and penalties nearby)
- State v. Heinemann, 282 Conn. 281 (2007) (legislative categorization of offenses as a cautious guide for courts)