The Supreme Court laid down four criteria for cases involving the involuntary administration of medication to an incompetent pretrial defendant. Decided June 16, 2003 (argued March 3, 2003). Opinion of the Court: Stephen Breyer → go there Dissenting: Scalia. Applied: the Sixth Amendment → go there Applied: the Fourteenth Amendment → go there Topic: Competence. Sell v. United States, 539 U.S. 166 (2003), is a decision in which the United States Supreme Court imposed stringent limits on the right of a lower court to order the forcible administration of antipsychotic medication to a criminal defendant who had been determined to be incompetent to stand trial for the sole purpose of making them competent and able to be tried. Specifically, the court held that lower courts could do so only under limited circumstances in which specified criteria had been met. In the case of Charles Sell, since the lower court had failed to determine that all the appropriate criteria for court-ordered forcible treatment had been met, the order to forcibly medicate the defendant was reversed. Wiki link