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| Judge Susie Morgan |
In early 2020, Bryant Lamont Harris called the chambers of district judge Susie Morgan to complain about the New Orleans Police Department and inquire about Judge Morgan’s security personnel. When pressed to provide a reason for wanting this information, Harris replied, “I need to know how many people I need to take out to get to the Judge.” This was not the first time Harris had made such calls to Judge Morgan’s chambers. Subsequently, Harris was arrested, detained, and charged with threatening to assault a federal judge. During a behavioral health analysis, Harris mentioned that he had received offers of “multiple women and $500k a month contract to join the Illuminati.” As a result of these claims, Harris was found to be delusional and incompetent to stand trial. He was then sent to an institution to receive psychiatric treatment for no more than four months.
During his stay, Harris refused to take medication, so it was recommended that he be involuntarily medicated. When the court held a hearing to determine if this was a viable course of action, Harris, a Jehovah’s Witness, raised an objection on the grounds of his religious beliefs. Although Jehovah's Witnesses do not reject all medical treatment, they believe that it is a personal choice to be treated medicinally. The court recognized Harris’s objections, but ultimately ruled that his religious liberty did not outweigh the compelling governmental interest in his prosecution; thus, it was ordered that Harris be forcibly medicated so that he may regain competence to stand trial. Feeling his religious liberties had been violated, Harris appealed.
On October 17, 2023, the 5th U.S. Circuit Court of Appeals noted the compelling governmental interest in this case, but drew attention to other factors that may diminish its importance. According to Sell v. United States (2003), a defendant can only be involuntarily medicated if the government can establish that “important governmental interests are at stake” while also considering that “special circumstances may lessen the importance of that interest.” The appeals court cited two “special circumstances” that must be considered: the amount of time Harris has been detained and his religious convictions. By October 2023,
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| 5th U.S. Circuit Court of Appeals |
At the core of this case is the conflict between state interest and religious freedom. Given Harris’s criminal charge and his fragile mental state, does the government have compelling interest to prosecute Harris and does it outweigh Harris’s right to free exercise of religion? Examining the precedent outlined in Sherbert v. Verner and the prongs of the Religious Freedom Restoration Act (RFRA) showcase that a high standard must be met before state interest can trump religious liberty. In Sherbert, the Supreme Court ruled in favor of Sherbert, a Seventh-day Adventist who contested that the denial of her unemployment benefits placed a burden on her ability to freely practice her faith. The court agreed that a substantial burden was imposed on Sherbert and that a compelling state interest could not be found to justify it. As a consequence of this ruling, the so-called “Sherbert Test” is applied in similar cases to determine if a compelling interest to restrict free exercise exists and if this restriction is implemented in the least burdensome manner possible; the RFRA essentially codified the Sherbert Test into law.
In my opinion, based on previous rulings and federal law, Harris was justified in appealing the original court’s decision that ordered he be involuntarily medicated. Although Harris’s potential for violent action gave the government compelling reason for his prosecution, the order for forced medication was not the least burdensome avenue. Theoretically, Harris could have undergone non-medicinal psychiatric treatment until he was competent to stand trial without betraying his religious beliefs. Under the Free Exercise clause, Harris has the right to refuse medication if he believes that the act of taking it is contrary to his religion. In other cases, religious exemptions have been provided for a wide variety of medical treatments and services. One can argue that Harris’s case differs because he is possibly a dangerous person, but his potential criminality does not strip him of his right to religious freedom. From my perspective, it is obvious that Harris’s right to free exercise was violated and the appeals court was correct in its voiding of the medication mandate.
Additional References:https://wng.org/roundups/appeals-court-considers-right-to-refuse-medication-1698177574
8 comments:
Hi Claire,
This was an incredibly engaging blog post. I agree that this case is interesting particularly because there is a clash between personal religious beliefs and the interest of the state. While the state did have a compelling interest to medicate Harris against his will, in practice, their plan is impractical and breaches Harris' beliefs beyond what should be seen as just. I appreciate your mention of the Sherbert case, and the fact that a high standard is set before religious liberty can be justly breached. As such, I agree with your opinion that Harris was justified in appealing his case and requesting a re-evaluation of his religious liberties.
Hey Claire,
Great post -- really enjoyed reading it. As you write, I also believe that the government should play a limited role, especially amid religion, in requiring medication. While you lay out an effective precedent in defense of Harris, I believe that this case may be more nuanced. More specifically, did Harris forfeit a genuine claim to a religious exemption after committing a violent crime?
Hi Claire
This was an incredibly interesting post. While I think that there was reason to be concerned for public safety, the government should have not breached Harris’s beliefs. I agreed with your analysis of the Sherbet test and agreed that there could have been less burdensome ways to help Harris. In this case, his right to his religious freedom should be more important than the state deciding that they wanted to medicate him. I found this case incredibly interesting and can see why it would be a difficult case to come to a decision on.
Hi Claire,
This was a very interesting case to read about! In particular, I found it very intriguing about this debate between an individual's personal religious beliefs and the government interests that are at stake. I do agree with your thinking of Harris being forced to take medication as unconstitutional and that they should look at non-medication routes, but I do disagree with some parts of this argument. Considering he was able to argue that it was his religious beliefs that did not allow him to take the medicine, he may have not been as delusional and incompetent as they think that he is, and the possibility could be that he is dangerous.
This is a super interesting case and I agree with your findings. It seems as if the court wanted to take the easiest road and found the defendant to be foolish, so they chose to medicate him in order to regain his competence. However, he had a legitimate claim of faith to refuse these medicines, and it was not like he was avoiding prison time while refusing the medication. Instead, he would have been unfairly punished as he would have had his religious rights trampled and his claims made inferior. I agree with you that there may be a compelling state interest to get the defendant help from his medical situation, however there appears to be other ways to do so, as you suggested.
Hi Claire,
This was an intriguing case that dealt with many different parts. I agree with you that Harris had a legitimate claim for his religious exemption of the medication. I believe the government stepped out of line in this case and could have came up with a different way in which Harris didn't have to infringe upon his religious beliefs. I do understand that he was delusional in a sense, but there could have been another way the government could have handled this situation.
Hi Claire,
The Harris case presents a complex clash between the government's interest in prosecuting a potentially dangerous individual and the right to religious freedom. The recent decision by the 5th U.S. Circuit Court of Appeals emphasizes the secular nature of "special circumstances" while considering the duration of Harris's detention and his religious convictions. Drawing on precedent cases like Sherbert v. Verner and the RFRA, it is clear that a high standard must be met before restricting religious liberty. In my view, Harris was justified in appealing the order for involuntary medication, as alternative avenues respecting both his religious beliefs and the state's interest should have been explored. The court's decision to void the medication mandate appropriately balances public safety concerns with preserving individual rights, and the government's motion for involuntary commitment introduces further complexity to the ongoing legal proceedings.
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