In Keyhea v. Rushen (1986) 178 Cal. App. 3d 526, 223 Cal. Rptr. 746, the court determined that the state violated section 2600 by subjecting prisoners to long-term involuntary medication without a judicial determination of competency, the assistance of counsel, a right to personal appearance, and adherence to procedural requirements delineated in the LPS Act. The court concluded that "state prisoners, like nonprisoners under the LPS statutory scheme, are entitled to a judicial determination of their competency to refuse treatment before they can be subjected to long-term involuntary psychotropic medication. Mental health professionals and prison administrators may find this requirement cumbersome, but this is a price of life in a free society. Forced drugging is one of the earmarks of the gulag. It should be permitted in state institutions only after adherence to stringent substantive and procedural safeguards." ( Keyhea v. Rushen, supra, at p. 542.) The LPS Act was found in Keyhea to provide "the sole mechanism for involuntary administration of long-term psychotropic medication, and also requires a court determination of incompetency." ( Id., at p. 541.) In the time of the Keyhea decision, section 2600 provided that prisoners may be deprived of only such civil rights as reasonably necessary for prison security or public safety. (178 Cal. App. 3d 526, 533, 223 Cal. Rptr. 746.) Penal Code section 2600 was amended in 1994 to add the Keyhea injunction, which provides that a prisoner in a state prison "may during that period of confinement be deprived of such rights, and only such rights, as is reasonably related to legitimate penological interests. Nothing in this section shall be construed to permit the involuntary administration of psychotropic medication unless the process specified in the permanent injunction, dated October 31, 1986, in the matter of Keyhea v. Rushen, 178 Cal. App. 3d 526, 223 Cal. Rptr. 746, has been followed. The judicial hearing for the authorization for the involuntary administration of psychotropic medication provided for in Part III of the injunction shall be conducted by an administrative law judge. . . ."