In Riggins v. Nevada (1992) 504 U.S. 127, the defendant was given a forced dosage of Mellaril, in a quantity large enough to cause a sedation-like effect and confusion and to place the dosage in the "toxic" range. (Id. at p. 137.) The Riggins court concluded that the administration of Mellaril at toxic levels likely affected the defendant's communication with counsel and comprehension of the trial. (Id. at pp. 137-138.) Because there was no showing that psychotropic medication was administered to the defendant because of any safety concerns or to accomplish an essential state policy, the Riggins court concluded the defendant had been denied a fair trial and reversed. (Id. at pp. 136-138.) The United States Supreme Court granted certiorari "to decide whether forced administration of antipsychotic medication during trial violated rights guaranteed by the Sixth and Fourteenth Amendments"; id. at 132-33; although the defendant had not specifically relied on the sixth amendment in seeking review. Id. at 152-53 (Thomas, J., dissenting). The court discussed the evidence presented at the defendant's hearing to terminate the forced medication of drugs in terms of the effect of the medication on the defendant's demeanor (sixth amendment) and on his thought processes (first amendment). The court concluded that "it is clearly possible that such side effects of the drug had an impact upon not just the defendant's outward appearance, but also the content of his testimony on direct or cross examination, his ability to follow the proceedings, or the substance of his communication with counsel." Id. at 137. The ability to follow the proceedings and to communicate with counsel relate directly to competency to stand trial.