Medina test (Colorado) · Go Syfert
← Colorado issues

Medina test in Colorado

58 Colorado opinions name it 2 courts 2016–2026 53 in the last five years

The cases below were cited by Colorado courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
People v. Medinagreen
colo · 1985 · cited in 32 Colorado opinions naming this issue, 2016–2026
2 sentences

2026People v. Medina, 705 P.2d 961, 973 (Colo. 1985). ¶ 19 Application of the Medina test involves mixed questions of fact and law.

2026People v. Medina, 705 P.2d 961, 973 (Colo. 1985). ¶ 19 Application of the Medina test involves mixed questions of fact and law.

432
Sell v. United Statesgreen
scotus · 2003 · cited in 3 Colorado opinions naming this issue, 2025–2026
2 sentences

2026A. Applicable Law and Standard of Review ¶ 10 Under the Medina test, a court may authorize the involuntary administration of medication if the petitioner demonstrates by clear and convincing evidence that (1) the patient is incompetent to effectively participate in the treatment decision; (2) the treatment is necessary to prevent a significant and likely long-term deterioration in the patient’s mental health condition or to prevent the likelihood of the patient causing serious harm to herself or others at the institution; (3) a less intrusive treatment alternative is not available; and 2 When

2026A. Applicable Law and Standard of Review ¶ 10 Under the Medina test, a court may authorize the involuntary administration of medication if the petitioner demonstrates by clear and convincing evidence that (1) the patient is incompetent to effectively participate in the treatment decision; (2) the treatment is necessary to prevent a significant and likely long-term deterioration in the patient’s mental health condition or to prevent the likelihood of the patient causing serious harm to herself or others at the institution; (3) a less intrusive treatment alternative is not available; and 2 When

33
in Interest of R.Fgreen
· 2019 · cited in 3 Colorado opinions naming this issue, 2024–2026
2 sentences

2026See People in Interest of R.F., 2019 COA 110 , ¶¶ 10-15 & n.1 (discussing the test from Sell v. United States, 539 U.S. 166, 180 (2003)).

2026See People in Interest of R.F., 2019 COA 110 , ¶¶ 10-15 & n.1 (discussing the test from Sell v. United States, 539 U.S. 166, 180 (2003)).

33
People ex rel. R.K.Lgreen
coloctapp · 2016 · cited in 4 Colorado opinions naming this issue, 2022–2025
2 sentences

2024People in Interest of R.K.L., 2016 COA 84, ¶ 30 . ¶ 15 Melrose doesn’t contest the district court’s rulings that the first, second, and fourth elements of the Medina test were met.

2024People in Interest of R.K.L., 2016 COA 84, ¶ 30 . ¶ 15 Melrose doesn’t contest the district court’s rulings that the first, second, and fourth elements of the Medina test were met.

24
People ex rel. M.K.M.green
coloctapp · 1988 · cited in 2 Colorado opinions naming this issue, 2016–2025
2 sentences

2025See M.K.M., 765 P.2d at 1076 . ¶6 Application of the Medina test involves mixed questions of fact and law.

2025See M.K.M., 765 P.2d at 1076 . ¶6 Application of the Medina test involves mixed questions of fact and law.

22
People v. Pflugbeilgreen
coloctapp · 1992 · cited in 1 Colorado opinions naming this issue, 2025–2025
2 sentences

2025See People v. Pflugbeil, 834 P.2d 843, 847 (Colo. App. 1992).

2025See People v. Pflugbeil, 834 P.2d 843, 847 (Colo. App. 1992).

11
People ex rel. Strodtmangreen
coloctapp · 2011 · cited in 1 Colorado opinions naming this issue, 2019–2019
2 sentences

2019People in Interest of Strodtman, 293 P.3d 123, 131 (Colo. App. 2011). 2 ¶7 “Applying the Medina test involves mixed questions of law and fact.” People v. Marquardt, 2016 CO 4, ¶ 8 , 364 P.3d 499, 502 .

2019People in Interest of Strodtman, 293 P.3d 123, 131 (Colo. App. 2011). 2 ¶7 “Applying the Medina test involves mixed questions of law and fact.” People v. Marquardt, 2016 CO 4, ¶ 8 , 364 P.3d 499, 502 .

11
People in Interest of CAKgreen
colo · 1982 · cited in 1 Colorado opinions naming this issue, 2019–2019
2 sentences

2019If supported by the record, a trial court’s findings and conclusions . . . will not be disturbed on review.” People in Interest of S.M.A.M.A., 172 P.3d 958, 962 (Colo. App. 2007); accord People in Interest of C.A.K., 652 P.2d 603 , 613 (Colo. 1982). ¶8 R.C. contests only the third element of the Medina test, asserting that the district court erred in finding that no less intrusive treatment alternative was available.

2019If supported by the record, a trial court’s findings and conclusions . . . will not be disturbed on review.” People in Interest of S.M.A.M.A., 172 P.3d 958, 962 (Colo. App. 2007); accord People in Interest of C.A.K., 652 P.2d 603 , 613 (Colo. 1982). ¶8 R.C. contests only the third element of the Medina test, asserting that the district court erred in finding that no less intrusive treatment alternative was available.

11
People Ex Rel. Smamagreen
coloctapp · 2007 · cited in 1 Colorado opinions naming this issue, 2019–2019
2 sentences

2019If supported by the record, a trial court’s findings and conclusions . . . will not be disturbed on review.” People in Interest of S.M.A.M.A., 172 P.3d 958, 962 (Colo. App. 2007); accord People in Interest of C.A.K., 652 P.2d 603 , 613 (Colo. 1982). ¶8 R.C. contests only the third element of the Medina test, asserting that the district court erred in finding that no less intrusive treatment alternative was available.

2019If supported by the record, a trial court’s findings and conclusions . . . will not be disturbed on review.” People in Interest of S.M.A.M.A., 172 P.3d 958, 962 (Colo. App. 2007); accord People in Interest of C.A.K., 652 P.2d 603 , 613 (Colo. 1982). ¶8 R.C. contests only the third element of the Medina test, asserting that the district court erred in finding that no less intrusive treatment alternative was available.

11
Goedecke v. State, Dept. of Institutionsgreen
colo · 1979 · cited in 1 Colorado opinions naming this issue, 2016–2016
2 sentences

2016It comes from a broader background, and it has been applied to other kinds of treatment.  Medina states that incompetent patients “have the right under appropriate circumstances to legitimately refuse treatment that poses a significant risk to their physical well-being,” 705 P.2d at 967 (emphasis added).  Goedecke v. State, Department of Institutions, 198 Colo. 407, 411 , 603 P.2d 123, 125 (1979), a case upon which the supreme court relied heavily in Medina, observed that 37 Colorado courts have historically “acknowledged” that doctors must obtain a competent patient’s informed consent “for

2016It comes from a broader background, and it has been applied to other kinds of treatment.  Medina states that incompetent patients “have the right under appropriate circumstances to legitimately refuse treatment that poses a significant risk to their physical well-being,” 705 P.2d at 967 (emphasis added).  Goedecke v. State, Department of Institutions, 198 Colo. 407, 411 , 603 P.2d 123, 125 (1979), a case upon which the supreme court relied heavily in Medina, observed that 37 Colorado courts have historically “acknowledged” that doctors must obtain a competent patient’s informed consent “for

11
Youngberg v. Romeo Ex Rel. Romeogreen
scotus · 1982 · cited in 1 Colorado opinions naming this issue, 2016–2016
2 sentences

2016“Persons who have been involuntarily committed are entitled to more considerate treatment and conditions of confinement than criminals whose conditions of confinement are designed to punish.” Youngberg v. Romeo, 457 U.S. 307, 321-22 (1982). ¶ 29 We conclude that a court, including this court, may not arrogate to itself the authority to impose such a treatment against the will of an individual who has been involuntarily committed to a mental health treatment facility. ¶ 30 The application of the Medina test to chemical castration, moreover, has far-reaching implications.

2016“Persons who have been involuntarily committed are entitled to more considerate treatment and conditions of confinement than criminals whose conditions of confinement are designed to punish.” Youngberg v. Romeo, 457 U.S. 307, 321-22 (1982). ¶ 29 We conclude that a court, including this court, may not arrogate to itself the authority to impose such a treatment against the will of an individual who has been involuntarily committed to a mental health treatment facility. ¶ 30 The application of the Medina test to chemical castration, moreover, has far-reaching implications.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Colorado. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
People v. Marquardt green
colo · 2016
2 sentences

2025Id. ¶6 Application of the Medina test involves mixed questions of fact and law.1 People v. Marquardt, 2016 CO 4, ¶ 8 .

2025Id. ¶6 Application of the Medina test involves mixed questions of fact and law.1 People v. Marquardt, 2016 CO 4, ¶ 8 .

442019–2026
People ex rel. R.K.L. green
coloctapp · 2016
2 sentences

2026Id. at ¶ 30, 412 P.3d at 834 . ¶ 11 The district court found that, even if the “litany” of reasons Horstmann gave for not wanting to take the medications were all bona fide and legitimate, her need for the medications was nonetheless sufficiently compelling to override those interests.

2026Id. at ¶ 30, 412 P.3d at 834 . ¶ 11 The district court found that, even if the “litany” of reasons Horstmann gave for not wanting to take the medications were all bona fide and legitimate, her need for the medications was nonetheless sufficiently compelling to override those interests.

32024–2026
Arizona v. Gant green
scotus · 2009
1 sentence

2026The cases on which he relies, Arizona v. Gant, 556 U.S. 332 (2009), and People v. Kessler, 2018 COA 60 , involved the search incident to arrest exception, not the automobile exception. 9 ¶ 22 Because we have already concluded that Deputy Guess had probable cause to search the SUV without a warrant, and there is no dispute that the SUV was readily mobile, the district court didn’t err by denying Medina’s motion to suppress.

12026–2026
v. Kessler green
coloctapp · 2018
1 sentence

2026The cases on which he relies, Arizona v. Gant, 556 U.S. 332 (2009), and People v. Kessler, 2018 COA 60 , involved the search incident to arrest exception, not the automobile exception. 9 ¶ 22 Because we have already concluded that Deputy Guess had probable cause to search the SUV without a warrant, and there is no dispute that the SUV was readily mobile, the district court didn’t err by denying Medina’s motion to suppress.

12026–2026
People v. Rockwell green
colo · 2006
1 sentence

2026P. 35(c), see Rockwell, 125 P.3d at 414 , and Medina didn’t advance it in his postconviction motion.

12026–2026
Washington v. Harper green
scotus · 1990
2 sentences

2025In Harper, the Court analyzed the due process protections afforded to mentally ill prisoners who refuse to take prescribed psychotropic medications and concluded that a state may administer medication to such individuals involuntarily “if the inmate is dangerous to 4 himself or others and the treatment is in the inmate’s medical interest.” Harper, 494 U.S. at 227 . ¶ 11 Relying on this language in Sell and Harper, Danford argues that, absent a finding that the person is “dangerous” or has “grave health concerns,” a court must apply the Sell test, and not the Medina test, to determine whether f

2025In Harper, the Court analyzed the due process protections afforded to mentally ill prisoners who refuse to take prescribed psychotropic medications and concluded that a state may administer medication to such individuals involuntarily “if the inmate is dangerous to 4 himself or others and the treatment is in the inmate’s medical interest.” Harper, 494 U.S. at 227 . ¶ 11 Relying on this language in Sell and Harper, Danford argues that, absent a finding that the person is “dangerous” or has “grave health concerns,” a court must apply the Sell test, and not the Medina test, to determine whether f

12025–2025
In Re The PEOPLE of the State of Colorado v. Delbert Ray VIGIL neutral
colo · 2021
2 sentences

2025Danford argues that, in her case, the magistrate erred by ordering the involuntary administration of medication in the absence of a finding of “grave health concerns.” Because we conclude the magistrate applied the correct legal standard, we affirm the involuntary medication order. ¶7 “Whether a court applied the correct legal standard presents a question of law that we review de novo.” People v. Vigil, 2021 CO 46 , ¶ 17, 488 P.3d 1150, 1154 . ¶8 A person has a significant constitutionally protected liberty interest in avoiding the unwanted administration of antipsychotic medications.

2025Danford argues that, in her case, the magistrate erred by ordering the involuntary administration of medication in the absence of a finding of “grave health concerns.” Because we conclude the magistrate applied the correct legal standard, we affirm the involuntary medication order. ¶7 “Whether a court applied the correct legal standard presents a question of law that we review de novo.” People v. Vigil, 2021 CO 46 , ¶ 17, 488 P.3d 1150, 1154 . ¶8 A person has a significant constitutionally protected liberty interest in avoiding the unwanted administration of antipsychotic medications.

12025–2025
People v. Medina green
· 2021
1 sentence

2023Moreover, the court found that the record provided sufficient grounds “to determine that there was a strong factual basis for the offense.” Accordingly, the court ruled that Medina’s plea was knowing and voluntary; it also ruled that “[t]here was a factual basis for the plea sufficient to meet the Alford requirements.” ¶12 Medina appealed, arguing that under Alford, his plea was invalid because the trial court allowed him to waive proof of a factual basis.3 People v. Medina, 2021 COA 124, ¶ 14 , 501 P.3d 834 , 837.

12023–2023
People v. Aguilar green
coloctapp · 2012
1 sentence

2019Id. ¶5 We note that in ruling on Medina’s motion, it appears that the district court did not address the requirements of the UMDDA.

12019–2019

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 24-51-1105 (10) CO § Colo. Rev. Stat. § 27-65-102 (8) CO § Colo. Rev. Stat. § 27-65-109 (6) CO § Colo. Rev. Stat. § 27-65-111 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CO 58 (2016–2026) CA 23 (1979–2026) TX 9 (1996–2019) AZ 4 (2013–2025) FL 3 (1997–2013) WI 3 (2021–2025) GA 2 (2020–2023) CT 2 (1996–2009) IL 2 (2010–2020) WA 2 (2012–2024) UT 2 (2019–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check