United States v. Frank Chatmon
2013 U.S. App. LEXIS 11644
| 4th Cir. | 2013Background
- Chatmon indicted for conspiracy to distribute crack cocaine and heroin; diagnosed with paranoid schizophrenia and ruled incompetent to stand trial.
- District court granted government motion to involuntarily medicate to restore competency under Sell v. United States framework.
- District court found important government interest and asserted no less intrusive means were available, but provided minimal analysis of alternatives.
- Chatmon was evaluated at Butner; December 9, 2011 report confirmed schizophrenia and noted potential efficacy of haloperidol decanoate.
- Chatmon was moved from solitary RMU to an open unit, showing behavioral improvements before the competency hearing; no additional competency evaluation occurred.
- The government filed the forced-mediation motion in February 2012; district court held a hearing August 29, 2012 and entered an order allowing involuntary medication,
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether third Sell factor was properly analyzed | Chatmon | Chatmon | Vacated; remanded for proper less-intrusive analysis |
| Whether less intrusive options were adequately considered | Chatmon urged group therapy/open-unit placement | Government claimed no effective less intrusive means | Remanded to consider less intrusive options and contempt-backed orders |
| Whether government interest qualified as 'important' under Sell | Chatmon | Government interests supported by serious crime charge | Remanded; order vacated pending proper findings |
Key Cases Cited
- Sell v. United States, 539 U.S. 166 (U.S. 2003) (four-factor test for involuntary medication to restore competency)
- United States v. White, 620 F.3d 401 (4th Cir. 2010) (drastic resort; liberty interests vs. government interests)
- United States v. Bush, 585 F.3d 806 (4th Cir. 2009) (clear standard for Sell factors)
- United States v. Evans, 404 F.3d 227 (4th Cir. 2005) (serious-crime criterion; maximum sentence governs seriousness)
- United States v. Green, 532 F.3d 538 (6th Cir. 2008) (example of upholding involuntary medication under Sell)
- United States v. Bradley, 417 F.3d 1107 (10th Cir. 2005) (example of considering less intrusive means under Sell)