United States v. Richard Springs
687 F. App'x 672
| 9th Cir. | 2017Background
- Defendant Richard Springs charged under 18 U.S.C. § 115(a)(1)(B) for threats to kill federal judges in the Western District of Washington.
- District court found Springs incompetent to stand trial and ordered hospitalization for restoration; Springs refused treatment.
- Government moved for involuntary medication under Sell v. United States to restore competency; district court granted the motion.
- Medical evidence showed Abilify (aripiprazole) was substantially likely to restore competency and had mild side effects; Springs had previously taken Abilify with symptom improvement and no serious side effects.
- Court found psychotherapy ineffective for Springs, considered less-intrusive measures (oral dosing first), and evaluated long-term medical interests.
- Springs appealed the Sell order; Ninth Circuit affirmed, concluding the four Sell factors were met by clear and convincing evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether important governmental interests support forced medication under Sell | Government: prosecution of threats to federal judges is a serious interest warranting restoration | Springs: special circumstances (low guidelines, long pretrial custody) lessen that interest | Held for government — interests are sufficiently important (serious crime, possible supervised release, deterrence) |
| Whether involuntary medication will significantly further government’s interest | Government: medication (Abilify) is substantially likely to render Springs competent and not impair assistance of counsel | Springs: contested risks/effects (no expert presented) | Held for government — evidence (unchallenged) showed substantial likelihood of competency restoration |
| Whether involuntary medication is necessary (no less intrusive means) | Government: psychotherapy proved ineffective; less-intrusive steps (oral dosing) ordered first | Springs: argued alternatives/less intrusion sufficed | Held for government — court found medication necessary after attempted alternatives failed |
| Whether recommended treatment is medically appropriate and in defendant’s best interest | Government: experts testified Abilify appropriate with mild side effects; benefits outweigh risks | Springs: opposed forced medication (but no expert contest) | Held for government — court found treatment medically appropriate and in defendant’s long-term medical interest |
Key Cases Cited
- Sell v. United States, 539 U.S. 166 (2003) (framework for involuntary medication to restore competency)
- Ruiz-Gaxiola v. United States, 623 F.3d 684 (9th Cir. 2010) (Ninth Circuit’s application of Sell; burden and review standards)
- Washington v. Harper, 494 U.S. 210 (1990) (permitting involuntary medication of inmates when dangerous and treatment is in their best interest)
- United States v. Gillenwater, 749 F.3d 1094 (9th Cir. 2014) (consideration of supervised release and deterrence in Sell-factor analysis)
- United States v. Onuoha, 820 F.3d 1049 (9th Cir. 2016) (evaluating governmental interests including deterrence and likelihood of civil commitment)