Background
Andrew Michael Keene was admitted to the Colorado Mental Health Hospital in Pueblo in December 2025 after being found incompetent to proceed in two criminal cases. He was diagnosed with type I bipolar disorder and experienced manic and psychotic symptoms, including persecutory delusions and aggressive behavior. Hospital staff began emergency medication after an incident in which he was verbally aggressive and physically postured toward staff.
The People sought authority to administer olanzapine, an antipsychotic, and lithium, a mood stabilizer, without Keene’s consent. Keene denied having bipolar disorder, though he acknowledged PTSD and depression, and preferred psychological treatment, Ativan, and melatonin. His psychiatrist, Dr. Zachary Wickline, testified that the requested medications were necessary to treat Keene’s severe condition and prevent deterioration and harm.
The Court’s Holding
The Colorado Court of Appeals affirmed the district court’s order authorizing involuntary medication. Because the petition was based on preventing significant, long-term mental-health deterioration and serious harm—not competency restoration—the court applied the four-part test from People v. Medina.
Viewing the evidence favorably to the People, the court held that Dr. Wickline’s testimony supported all four Medina elements by clear and convincing evidence. Keene’s lack of insight into his bipolar disorder supported the finding that he could not effectively participate in the treatment decision; the medications were necessary to avert deterioration; no equally effective, less intrusive alternative existed; and Keene’s need for treatment outweighed his claimed interest in avoiding side effects.
Key Takeaways
- A treating physician’s credited testimony may alone support a Medina involuntary-medication order.
- A patient’s recognition of other conditions does not establish capacity when the patient lacks insight into the illness requiring treatment.
- Therapy, sleep aids, and anti-anxiety medication were not equally effective substitutes for the requested antipsychotic and mood stabilizer.
Why It Matters
The decision illustrates how Colorado courts assess involuntary psychiatric medication when the purpose is protecting a hospitalized patient’s health and institutional safety rather than restoring criminal competency. It also underscores the deference appellate courts give to trial courts’ credibility determinations when conflicting testimony concerns diagnosis, treatment efficacy, and medication side effects.