A grand jury indicted Chalifoux in February 2021 on counts including conspiracy to distribute 50 grams or more of methamphetamine and distribution of heroin. Chalifoux entered a plea agreement and pled guilty to Count One. However, before sentencing, his counsel withdrew twice, and new attorneys were appointed.
Chalifoux moved to withdraw his guilty plea, claiming prior counsel failed to adequately explain the agreement. During a hearing on that motion, his counsel raised the issue of competency and moved for a psychological evaluation. The court granted the motion, and a magistrate judge appointed Dr. Randy K. Otto to examine Chalifoux.
Dr. Otto’s forensic psychological evaluation recommended that the court consider Chalifoux unable to understand the proceedings or assist in his defense due to paranoid thinking. The government subsequently moved for a competency hearing under 18 U.S.C. § 4241.
At the May 2022 competency hearing, Dr. Otto testified that Chalifoux was not competent but could be restored with treatment, identifying medication as the primary mechanism. The magistrate judge agreed, finding Chalifoux incompetent due to a delusional disorder and ordering him committed to the custody of the Attorney General for hospitalization.
In September 2023, a Bureau of Prisons forensic psychologist reported that Chalifoux remained incompetent but had a substantial probability of restoration if authorized to receive antipsychotic medication. The government moved for a hearing under Sell v. United States, which sets the standard for involuntary medication.
During the May 2024 hearing, government experts Dr. Sarah Burton and Dr. Shawn Rice testified that Chalifoux suffered from delusional disorder, persecutory type. Dr. Burton stated that less intrusive treatments would not work because Chalifoux’s beliefs were fixed and paranoid, requiring medication to address.
Chalifoux’s expert, Dr. Richart DeMier, largely agreed with the government’s experts but noted Chalifoux had refused to be interviewed. The magistrate judge recommended granting the government’s motion, finding the government met all Sell factors by clear and convincing evidence.
Chalifoux objected to the recommendation, arguing he was unable to testify. The district court overruled the objection, noting Chalifoux had not asked to testify until after the recommendation was prepared. The court granted the motion, and Chalifoux appealed.
The Eleventh Circuit affirmed, holding that the government demonstrated an important interest in bringing Chalifoux to trial for serious offenses. The court found no clear error in the district court’s determination that involuntary medication was necessary and medically appropriate to restore competency.