affirmed Riggins' convictions and death sentence. Riggins then petitioned the U.S. Supreme Court. Opinion of the Court The Supreme Court reversed and remanded, holding that forced administration of antipsychotic medication during Riggins' trial violated his rights guaranteed under the Sixth and Fourteenth Amendments. A seven-member majority held that the state did not show that antipsychotic medication was medically appropriate and did not demonstrate that it considered less intrusive means in obtaining its goal of trying Riggins. The Court stated that Riggins' Eighth Amendment argument that the forcible administration of antipsychotic medication denied him the chance to show the jury his true mental state at the sentencing hearing was not raised in the petition for certiorari and therefore was not addressed by the court. The Court held that a person awaiting trial has a valid reason, protected under the due process clause, to refuse antipsychotic drugs, referencing Washington v. Harper (1990) and Bell v. Wolfish (1979). Therefore, once Riggins' requested termination of the medication, the State was obligated to establish both the need for the antipsychotic drug and its medical appropriateness for Riggins' safety and that of others as the less restrictive alternative available. If the state had done this, due process would have been satisfied. The State might have been able to justify the treatment, if medically appropriate, if it set forth that the adjudication of guilt or innocence could not be established by using less intrusive means. Since the trial court did not do this and allowed the drug's administration to continue without making any of the determinations stated above, it is very likely that this error violated Riggins' trial rights established by the Constitution. However, this is only speculative as there is no way to know what the outcome would have been if the proper course had been followed. Significance This decision highlighted two factors not previously emphasized in cases involving involuntary medication. First, the involuntary treatment must be the least intrusive treatment for restoration of competence. Second, the proposed treatment must be medically appropriate for the individual's safety as well as that of others. In Washington v. Harper, the individual protesting the involuntary medication was already incarcerated. The Court suggested in this case that a competent person has the right to refuse if the medication is administered for other than treatment reasons to a person not dangerous or extremely ill, but it accepted the institution's procedures for