Forced Medication OK'd as Supervised Release Term

US v. Holman: While Holman was incarcerated for drug offenses, he was diagnosed with a mental illness that required medication. Holman would regularly refused to take medication voluntarily, leading to him being administered intramuscular antipsychotic meds against his will. When released, he was given a supply of oral medication and instructions on when to take it. It was recommended that he continue the injections as well, to guard against going off his meds altogether. The initial conditions of this supervised release neither required mental health treatment nor medication. However, those conditions were modified to require such treatment, including injections. Holman violated his supervised release twice, the second time by refusing to take his meds. He appealed both the length of his 12-month sentence as well as the continued condition that he submit to the injections. The Fourth Circuit affirmed, holding that the condition did not violate Holman's due process right to be free from unconsensual medical treatment, given the evidence that Holman was a danger to himself and others in an unmedicated state.