In the case of Washington, et al. v. Walter Harper in 1989, the U.S Supreme Court ruled that a state could administer antipsychotic drugs to prison inmates against their will under certain circumstances without violating their constitutional rights. The court held that an inmate's interest in avoiding unwanted medication was outweighed by the state's twin interests in providing appropriate medical care to its prisoners and maintaining institutional security and order. However, this decision is subject to specific conditions: firstly, it must be determined by a medical professional that the treatment is in the patient’s best interest; secondly, there should be serious concerns about safety if left untreated; thirdly, less intrusive treatments have been considered but found inappropriate.

In the dissenting opinion for Washington, et al. v. Walter Harper, Justice Stevens argued that forcibly medicating a prisoner without his consent violated his constitutional rights to privacy and freedom from bodily intrusion unless it was necessary to prevent harm to himself or others. He contended that the majority's decision gave too much power to prison officials and medical personnel at the expense of individual liberty interests. Furthermore, he believed that this case should have been evaluated under a strict scrutiny standard rather than rational basis review because forced medication is an extreme infringement on personal liberties. Under such scrutiny, he felt there were less intrusive means available for dealing with mentally ill prisoners who refuse treatment.