Steele v. Hamilton County Mental Health Board (2000) 90 Ohio St.3d 176
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Steele v. Hamilton County Mental Health Board
The case between Steele v. Hamilton is principal in the determination of the right to force medication on patients where the patient is unwilling or incapable of consenting to the medication. To date, this issue remains controversial since most states have resorted to reducing their facilities for involuntary commitment and further restricted the right to medicate patients without their prior consent. From this point of view, medical attendants argue that it is not worth the risk to deprive medication to willing patients who pose imminent danger to others if not treated. Hence, it is typical for such hospitals to release these patients in a bid to allow enough space and resources for patients who do not refuse medication. In this connection, the police took Jeffery Steele for hospitalization after his family reported that he was communicating and relating with nonexistent objects. After his admission, the attending physician noted that the patient was responding to internal stimuli and thus required treatment for treating psychosis (Szasz, 2002). Reports filed by doctors compelled the Court to rule that Steele should continue with his hospitalization as it deemed he had a mental illness. Thus, Steele was transferred to Lewis Care Center where the Hamilton County Community Mental Health sought a Court order to permit employees induce medication to the appellant without his consent.
According to the psychiatrics who testified at the hearing, the appellant was suffering from a case of schizophrenia. Secondly, the appellant while in the hospital did not pose any danger to himself or to others. Thirdly, the appellant lacked the capacity to provide or withhold informed consent. Fourthly, the only treatment available for the patient’s illness was the anti-psychotic medication. Fifthly, the benefits of the said medication outweighed the side effects. Lastly, without this medication, the patient would have to be detained in the hospital. Nevertheless, the magistrate denied the application using the finding that there was no clear evidence to justify that the appellant held immediate grave danger to other persons or to himself. Hence, the Court upheld the refusal to allow medication.
The Ohio Supreme Court distinguished the probate’s Court capacity to determine that an involuntary hospitalized ill person was deemed as likely to cause risk to him/herself or others and that a Court may issue an order to permit employees to administer anti-psychotic medication to the patient without his or her consent. Hence, the Supreme Court weighed two objectives: the desire to treat a patient to improve his or her condition when he or she is incapable of consenting and two, the severe intrusion of individuals’ personal autonomy by forceful administration of drugs. From this perspective, the Court presented a three-part test that can be used to determine the Court’s role to overrule the patient’s right to refuse medication. Here, the physician must determine that the patient presents an impending danger of harm to others or self. Secondly, the physician must ascertain that there are no other alternatives (other than medication) of eluding harm. Thirdly, the physician must provide his or her approval that the medication to be administered is medically appropriate for the patient. In this case, the Court asserted that where a patient did not pose any threat against others, it was up to the Court to ensure provision of care to patients who are unable to care for themselves (AMA, 2002). Since this ruling, many agencies in Ohio discharge patients rather than proceed to seek a Court order for treatment (AMA, 2002).

References
AMA, Press. (2002). Code of Medical Ethics: Current Opinions and Connotations. Southern Illinois University at Carbondale.
Szasz, T. (2002). Liberation by oppression: a comparative study of slavery and psychiatry. Transaction Books.