United States v. Diaz, 630 F.3d 1314

Diaz was involuntarily medicated to render him competent to stand trial for multiple armed-robbery and firearm offenses.
A prior competency hearing had found Diaz competent; later proceedings found him incompetent, leading to involuntary-medication proceedings.
Springfield medical center conducted due-process and Sell hearings to determine whether involuntary antipsychotic medication could restore Diaz’s competency.
The district court concluded the government satisfied Sell factors and ordered involuntary medication after attempts at voluntary treatment failed.
Diaz challenged the decision, arguing the government failed to prove the second and third Sell factors by clear and convincing evidence.
The Eleventh Circuit affirmed, holding de novo review for the first Sell factor and clear-error review for the remaining factors, and upholding the district court’s findings and order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the government met the Sell factors by clear and convincing evidence.	United States argued factors 2–4 satisfied; statistics and expert testimony show substantial restoration likelihood.	Diaz contends factors 2–3 not proven; medication not necessary or likely to render him competent.	No error; government proved factors 2–3 by clear and convincing evidence.
Whether involuntary medication significantly furthered government interests under Sell factor 2.	United States showed substantial likelihood of restoration and minimal adverse impact on defense.	Diaz argued low likelihood and potential side effects would impair defense.	Not clearly erroneous; factors supported by expert testimony and data.
Whether involuntary medication is necessary under Sell factor 3.	United States demonstrated less intrusive options unlikely to achieve substantial results and Diaz refused treatment.	Diaz argues alternative approaches could suffice and less intrusive means exist.	Not clearly erroneous; less intrusive options unlikely to achieve restoration given Diaz’s refusals.

Sell v. United States, 539 U.S. 166 (U.S. 2003) (four-factor framework for involuntary medication to render defendant competent; substantial still rare)
Fazio, 599 F.3d 835 (8th Cir. 2010) (first factor reviewed de novo; others are clear-error (practice in Sell cases))
Green, 532 F.3d 538 (6th Cir. 2008) (second and fourth factors reviewed for clear error; first factor de novo)
Gomes, 387 F.3d 157 (2d Cir. 2004) (supports that second Sell factor can be satisfied by medical testimony and data)
Evans, 404 F.3d 227 (4th Cir. 2005) (review of Sell factors for clear error where applicable)