Riggins v. Nevada

In 1987, David Riggins (defendant) was arrested for the murder of Paul Wade. While in custody, Riggins was treated with an antipsychotic drug after telling a doctor that he was having auditory hallucinations. Riggins’s dosage was increased to 800 milligrams a day. During Riggins’s competency trial, Riggins was treated with a lower dose and evaluated by three court-appointed psychiatrists. Two doctors found Riggins to be competent, and the third found Riggins incompetent. One of the doctors also stated that Riggins would become incompetent without the medication. The court held that Riggins was competent to stand trial. Later, Riggins moved the court to order the discontinuation of the medication. Riggins argued that as part of his insanity defense he had the right to show the jury his unaltered mental state and that the medication’s impact on his demeanor would violate his due-process rights. At an evidentiary hearing, three doctors testified. Two doctors stated that Riggins would still be competent even if taken off the medication, and one doctor indicated that the doctor was not sure what the results would be. The doctors also indicated that Riggins was on a high dose of the drug, which could make him confused and drowsy. The judge denied Riggins’s motion and ordered involuntary administration of the medication. The jury convicted Riggins of murder and robbery and sentenced him to death. The Nevada Supreme Court affirmed and found that the expert testimony regarding the administration of the antipsychotic drug was sufficient for the jury to understand the drug’s impact on Riggins’s behavior. The United States Supreme Court granted review.