Can A State Forcibly Medicate An Inmate To Make Him Competent To Be Executed? Singleton v. Norris (2003)

Charles Singleton, executed in 2004 for the 1979 murder of Mary Lou York

On June 1, 1979, Charles Singleton twice stabbed Mary Lou York, the owner of a grocery store in York, Arkansas, while she was working. Although she did not die instantly, she passed away hours later at a hospital due to excessive blood loss.

After he was convicted and sentenced to death, psychiatrists diagnosed Mr. Singleton with Schizophrenia and concluded he was only legally sane if he was medicated. The US Supreme Court already ruled that someone who is insane cannot be executed, as that would constitute cruel and unusual punishment (a violation of the Eighth Amendment). In order to be sane, a person must essentially understand the punishment will result in death and have a rational understanding of why he was sentenced to death (ex: if a person thinks he is being executed because alien overlords have infiltrated the government and they are trying to silence him, that person would be legally insane).

Mr. Singleton took antipsychotic medication voluntarily for a period of time, but he eventually refused to continue with his medication regimen. His doctors determined he was a danger to himself and others in prison when unmedicated, and he was thus forced to take his medication by court order.

His attorneys appealed his death sentence, as they argued the only thing keeping him eligible for such a penalty was his forced antipsychotic medication. They further argued that because his medication would eventually get him killed, it was no longer in his best interest medically to continue taking it. And, if he stopped taking it, he would quickly decompensate and no longer be eligible for the death penalty. Mr. Singleton's attorneys argued there was precedent against executing an "artificially competent" individual.

One major catch: Mr. Singleton admitted he felt much better when he was taking his medication and that he did not like being psychotic.

Mr. Singleton's case made its way to the Eighth Circuit Court of Appeals, which found that  "(1) as petitioner preferred to take the medication rather than remain in a psychotic state, and as he suffered no substantial side effects, the State's interest in carrying out the sentence outweighed petitioner's interest in avoiding medication; (2) petitioner's due process interests in life and liberty were foreclosed by the lawfully imposed death sentence and the procedures for imposing medication; and (3) the Eighth Amendment did not prohibit executing a prisoner who had become incompetent while on death row but who regained competency through appropriate medical care." 

His attorneys appealed to the US Supreme Court, which chose not to hear his case. Thus, the Appeals Court decision stood, and his stay of execution was vacated. Although his case made it to the Supreme Court for unrelated appellate reasons, Arkansas ended up executing Mr. Singleton on January 6, 2004.

Although this case opens the door for states to consider forcibly medicating individuals for the sole purpose of restoring them to competency to be executed, it did not answer the question of whether it is constitutional to do so. In Mr. Singleton's case, he admitted he felt better when he was taking his antipsychotic medication, and he was taking it voluntarily for a long period of time. Plus, his doctors determined he was a danger to himself and others when he was off of his medication, which was their rationale for asking the court to order forced medications--his psychiatrist was not asking the court to medication Mr. Singleton for the purposes of execution.