Fourth Circuit upholds suprevised release requirement of intramuscular injections of antipsychotic drugs

In United States v. Holman, the Fourth Circuit Court of Appeals considered the propriety of a condition of supervised release requiring that Holman participate in mental health treatment and take all prescribed medication, including intramuscular injections of an antipsychotic drug. Holman challenged the condition of supervised release as violating protected liberty interest. The Fourth Circuit Court of Appeals affirmed the district court’s decision. The court found that there was ample evidence that when Holman is off his medication he poses a danger to himself and others. The court also noted that the district court’s order was narrowly tailored to the circumstances of the case because Holman only became a danger when he was off his medication and long-lasting antipsychotic drugs provide the only means of insuring that Holman take his medication. Holman had a long history of non-compliance with medication while in prison. Finally, the record established that the involuntary-medication requirement was medically appropriate. Prison officials were generally required to use injections to stabilize Holman’s condition once he quit taking his oral medications, and Holman’s prison psychiatrist believed that the injections were his best treatment option because they prevented Holman from succumbing to the temptation to stop taking his medicine.