NOTE: Woodland v. Angus: The Right to Refuse Antipsychotic Drugs and Safeguards Appropriate for Its Protection Skip over navigation
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Copyright (c) 1994 Utah Law Review Society
Utah Law Review

NOTE: Woodland v. Angus: The Right to Refuse Antipsychotic Drugs and Safeguards Appropriate for Its Protection


1994 Utah L. Rev. 1169


Chris R. Hogle


I. Introduction

On March 28, 1990, a gunman emptied his .38-caliber revolver into Bruce Larson in Salt Lake City. 1 At the scene of the killing, police arrested Eugene Nate Woodland, 2 who was later charged with second-degree murder and aggravated assault. 3 After a determination that Woodland was incompetent to stand trial, he was committed to the Utah State Hospital. 4 While committed, Woodland was diagnosed as suffering from certain mental disorders and, over Woodland's objections, he was forcibly administered antipsychotic medication. 5

These events, which led to Woodland's civil rights action against the state hospital in Woodland v. Angus, 6 present a problem with no easy answers. Woodland, and those similarly situated, has an interest in refusing antipsychotic drugs, which, as this Note discusses in Part II, are perhaps the most dangerous drugs marketed in the United States. However, as this Note asserts in Part III, Utah also has a legitimate interest in attempting to treat Woodland's mental illness with the most effective means available--antipsychotic drugs. This dilemma, in similar form, has plagued the dockets of many courts for at least twenty years.

Part IV discusses the United States Supreme Court's recent contribution to a just resolution of the problem. The Court explicitly refused to develop concrete standards to deal with the competing interests of a mental patient and a state government when dealing with the forced administration of antipsychotic drugs. However, a careful examination of Supreme Court precedent and public policy reveals three guidelines. ...
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