Can a state, without violating due process or the Eighth Amendment, forcibly medicate a mentally ill inmate when the medication would render the inmate competent to be executed? The Eighth Circuit has held that due process is not violated so long as the state shows that there is an essential state interest that outweighs the inmate's interest in remaining free from the medication, that there are no less intrusive measures by which to accomplish the state interest, and that the medication is in the inmate's best medical interest. This Comment argues that in Singleton v. Norris, the Eighth Circuit improperly found that the imposition of the death penalty is an essential state interest, and also was wrong to conclude that medication is in the inmate's best medical interest even though the effect of the medication will be death. The Eighth Circuit further held that executing an artificially competent inmate is not cruel and unusual punishment, reasoning that, because the state was otherwise under an obligation to administer the medication, any other effect was irrelevant. In response, this Comment argues first, that the court incorrectly equated artificial sanity with true sanity, and second, that because courts and medical professionals make mistakes in determining competency, the fact that the death penalty is involved cannot be irrelevant.

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