United States v. Clayton Claflin, 670 F. App'x 372

Defendant Clayton Eric Claflin charged with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
District court ordered involuntary antipsychotic medication to restore competency to stand trial under the Sell framework.
On appeal, Claflin argued the district court failed to properly apply Sell and raised three special circumstances undermining the Government’s interest: likely civil commitment if not medicated, time already served making prosecution less important, and medication would prevent him from presenting a defense based on following directions of law enforcement/acting as an informant.
District court found evaluating doctors believed antipsychotic medication would likely restore competency if taken over sufficient time; Claflin historically responded to medication but refused to adhere to regimens.
The court also found Claflin was not likely to be civilly committed (not a danger), the Government retained a strong interest given threats to kill federal agents and others, and competency restoration would not bar an insanity defense.
Fifth Circuit affirmed, concluding no plain error in the Sell analysis and no clear error in the factual finding that medication was substantially likely to restore competency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court properly applied Sell to authorize involuntary medication	Sell factors not properly weighed; special circumstances reduce Government’s interest	Government: Sell factors satisfied; medication necessary for trial and restoration likely	Affirmed — no plain error in Sell analysis
Whether potential civil confinement negates Government’s interest	If not medicated, likely confined in mental hospital, reducing need to prosecute	Government: doctors opined not likely to be dangerous; confinement unlikely; interest remains	Rejected — potential confinement affects but does not defeat Government’s interest
Whether pretrial detention length negates prosecution interest	Time already served likely exceeds guideline sentence, reducing interest	Government: possible upward variance based on threats; sentence uncertain; interest remains	Rejected — length of detention does not defeat interest
Whether medication would prevent presentation of defenses	Medication would impair ability to present defense that conduct was directed by law enforcement/informant role	Government: competency restoration does not preclude presenting insanity-related defenses; competency and sanity are distinct	Rejected — competency restoration does not bar presenting insanity or other defenses

Sell v. United States, 539 U.S. 166 (2003) (framework for involuntary medication to restore competency)
Puckett v. United States, 556 U.S. 129 (2009) (plain-error review standard)
United States v. Palmer, 507 F.3d 300 (5th Cir. 2007) (governmental interest in prosecution despite psychiatric history and threats)
United States v. Fratus, 530 F.2d 644 (5th Cir. 1976) (distinction between competency to stand trial and insanity defense)