Travis Bean v. Dolly Matteucci
986 F.3d 1128
| 9th Cir. | 2021Background
- Bean was charged with two counts of murder (Sept. 2016) and in Dec. 2016 was found incompetent and committed to Oregon State Hospital (OSH) for evaluation and treatment.
- OSH doctors concluded antipsychotic medication was necessary to restore competency but OSH could not involuntarily medicate because Bean was not dangerous to self or others.
- The state sought and the Douglas County Circuit Court, after a Sell hearing, authorized involuntary antipsychotic medication to restore competency (July 16, 2018).
- Bean sought mandamus in the Oregon Supreme Court, which denied relief; he then filed a § 2241 habeas petition in federal district court seeking to enjoin the Sell order.
- The district court abstained under Younger v. Harris and denied the habeas petition; the Ninth Circuit granted a COA on the Younger abstention question.
- The Ninth Circuit majority reversed, holding the irreparable-harm (extraordinary circumstances) exception to Younger applied because forced medication is a severe, unreviewable liberty invasion; the case was remanded for further proceedings on habeas cognizability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention required dismissal of Bean’s federal habeas challenging the state Sell order | Younger does not apply because involuntary medication causes irreparable, unreviewable harm — extraordinary circumstances exception applies | Younger applies: ongoing state prosecution implicates important state interests and state remedies were available; the exception is narrow | Court: Younger factors satisfied but the irreparable-harm/extraordinary-circumstances exception applies; district court erred in abstaining; reversed and remanded |
| Whether the district court had subject-matter jurisdiction to hear Bean’s petition under 28 U.S.C. § 2241 (Nettles cognizability question) | § 2241 confers jurisdiction for pretrial habeas; court may reach merits if claim lies at core of habeas | Claim is not core habeas (should proceed, if at all, under § 1983); Nettles limits habeas to claims that necessarily affect confinement/duration | Court: federal jurisdiction exists in principle but left cognizability for the district court to decide on remand (did not resolve whether claim must be converted to § 1983) |
| Whether forcible administration of antipsychotics is the sort of pretrial right that cannot be vindicated post-trial | Forcible injection is a particularly severe, physical and mental liberty invasion that cannot be undone after trial — immediate review required | State stresses comity and trial-related interests; argues relief would unduly interfere with prosecution and that post-trial remedies or state review suffice | Court: forcible medication is a severe, unreviewable liberty deprivation (citing Sell/Riggins/Harper); post-trial review is inadequate, so the irreparable-harm exception applies |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (1971) (abstention doctrine barring federal interference in certain ongoing state proceedings)
- Sell v. United States, 539 U.S. 166 (2003) (framework permitting involuntary medication to restore competency only under narrow conditions)
- Nettles v. Grounds, 830 F.3d 922 (9th Cir. 2016) (en banc) (distinguishing core habeas claims from § 1983 claims for state prisoners)
- Page v. King, 932 F.3d 898 (9th Cir. 2019) (Younger exception where pretrial detention violated due process and could not be vindicated after trial)
- Arevalo v. Hennessy, 882 F.3d 763 (9th Cir. 2018) (Younger exception applied for extended pretrial detention without constitutionally adequate bail hearing)
- Riggins v. Nevada, 504 U.S. 127 (1992) (recognizing forced antipsychotic medication as a substantial liberty intrusion)
- Washington v. Harper, 494 U.S. 210 (1990) (due process protection against involuntary medication of prisoners)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998) (jurisdictional principles; absence of a valid cause of action is distinct from subject-matter jurisdiction)