Washington v. Harper

In Washington v. Harper (1990) 494 U.S. 210, the United States Supreme Court similarly held that prison officials may administer unwanted psychotropic drugs only when an inmate's mental disability poses a threat to himself or prison safety. The court decided that a procedure in which a psychiatrist ordered or approved the medication and the inmate was entitled to a hearing before a special committee consisting of a psychiatrist, a psychologist, and the associate superintendent of the treating facility, none of whom could be, at the time of the hearing, involved in the inmate's treatment or diagnosis, comported with the demands of the due process clause. (494 U.S. at pp. 215-216, 221-222.) The extent of a prisoner's right under the due process clause to avoid the unwanted administration of antipsychotic drugs was defined by the court in the context of the inmate's confinement, and the proper standard for determining the validity of a prison regulation claimed to infringe on an inmate's constitutional rights was stated as whether the regulation is " 'reasonably related to legitimate penological interests.'" ( Id., at pp. 222-223.) The court held that "the Due Process Clause permits the State to treat a prison inmate who has a serious mental illness with antipsychotic drugs against his will, if the inmate is dangerous to himself or others and the treatment is in the inmate's medical interest." ( Id., at p. 227.) It also held that "an inmate's interests are adequately protected, and perhaps better served, by allowing the decision to medicate to be made by medical professionals rather than a judge." ( Id., at p. 231.)