Could biotech solution reduce trauma of forced meds in prisons?

Key takeaways

• Biotech medication delivery could reduce prison use-of-force incidents: Implantable drug delivery systems (IDDS) may minimize confrontations during court-ordered medication, improving safety for staff and incarcerated individuals.
• California prisons face rising mental illness and involuntary medication cases: With over 33% of incarcerated persons diagnosed with mental illness, CDCR reports thousands of use-of-force incidents tied to forced medication.
• Current forced medication practices carry legal, ethical and financial risks: Litigation costs from mental health-related lawsuits in CDCR reached over $23 million in FY 2022–2023, highlighting the need for safer alternatives.
• Post-incarceration trauma linked to forced psychiatric interventions: Use of force during medication can deepen distrust, delay rehabilitation and increase the risk of post-incarceration syndrome.

By Acting Chief Deputy Warden Yesha Hill

The air in the housing unit was thick with tension as boots shuffled into formation. With human feces smeared about the interior of the cell, Bobo remained at the back of the cell, fingers twitching, shallow breaths and erratic movements as she screamed for staff to go away from her cell. Bobo yelled, “I am not taking that poisoned medication, you guys are just trying to kill me! If you come in here, I have orders from the government to kill you first!”

Correctional staff donned their protective gear, each piece designed to ensure safety, security and control prior to entering the cell to administer court-ordered medication to Bobo, who is in the midst of a psychotic breakdown. The shield officer carried a large, transparent polycarbonate riot shield, designed to absorb impact and push the incarcerated person against a surface once beyond the threshold of the cell door. Staff were suited with riot helmets, made with a face shield snapped down to protect against spitting, biting or sudden blows. Padded riot gear and gloves with impact-resistant padding covered their chest, shoulders, arms and legs, reinforced with rigid panels to absorb strikes; shields and batons were in hand to defend if the situation escalated beyond control holds. The team had zip ties, hand and leg restraints; a nurse stood nearby with gloves, holding a syringe filled with the court-ordered medication that led to this intervention.

The response supervisor, Sergeant Johnson, begged Bobo to surrender to handcuffs and receive her medication. “Bobo, this is your last chance. We want to help you,” pleaded Sergeant Johnson.

With all staff in place, ready to go, and the approval of the Incident Commander, the response supervisor gave a final nod, the door unlocked and the immediate cell entry ensued. Bobo was rushed by correctional staff, who began slipping in what appeared to be urine and feces on the cell floor, now splashing onto their personal protective equipment as they tried to restrain and gain compliance from Bobo. She began screaming, believing her life was in great danger. Bobo ran toward staff as they entered the cell and was met with the shield. Pinned to the floor, face down, she began thrashing her body in an attempt to free herself. Her arms were quickly pinned behind her back and handcuffed, and her legs placed in leg restraints. When it was safe to do so, the nurse entered the cell and rapidly administered the injection into Bobo’s right arm. Within seconds, Bobo slowed her resistance, breathing slowed, tears running down her face as staff prepared to exit the cell, their adrenaline still surging.

Incarcerated person Bobo, diagnosed with bipolar disorder and schizophrenia, had long refused her court-ordered antipsychotic medication. She believed the medication was poison to her body and the staff were partnering to control her mind and cause her harm as part of a “government order administered by aliens.” Although the incident itself was concluded and the job was considered “done,” Sergeant Johnson couldn’t shake the visual of Bobo pinned on the floor, crying and screaming in fear of her life. California Penal Code (PC) 2602 and corrections policy suggest the team did the right thing; Johnson, though, is questioning himself as to what the “right” thing really was.

After report writing and the shift concluded, the shield officer, Correctional Officer Ryann, passed the cell where Bobo was rehoused and couldn’t help noticing her sitting in a corner, tears running down her face, while in fetal position. Their eyes met as he passed the cell door, and guilt immediately consumed him as he read the distrust Bobo’s face was spelling out. Ryann took a deep breath and was off to his family, who had no idea what kind of day he had endured.

The problem — how we got here

Although our story is fiction, it represents the truth of daily life in corrections. This is only one of many instances where correctional staff must forcibly enter cells to administer court-ordered medication. This experience is one that leaves a searing impression on staff every time, as if it were their first time. Tragically, instances such as this are on the rise.

The prevalence of mental health disorders among the incarcerated has risen markedly, intensifying the demand for adequate mental health services in the state’s correctional facilities.

In April 2000, approximately 12.5% of California’s incarcerated individuals had a diagnosed mental illness. By 2022, approximately 33%of the incarcerated population was determined to have a diagnosed mental illness, almost triple the number from only two decades before. [1] At this rate, nearly 50% of the incarcerated population in California will be diagnosed with a mental illness within the next 10 years. As the number of incarcerated persons diagnosed with severe mental illnesses increases, the reliance on involuntary medication, particularly in emergency situations, has increased as well. As correctional leaders try to keep their staff safe, the courts have weighed in to alter the policies and processes they use to control persons in their care.

To better understand the ways these issues impact organizations, we will look at the experiences and lessons learned from one of the largest correctional systems in the world, the California Department of Corrections and Rehabilitation (CDCR). Although CDCR’s setting is multi-site and complex, the issues it faces are also ones for which every custody setting in the nation experiences are similar.

On September 13, 1995, a federal court in Sacramento, California, (Coleman v. Wilson, now known as Coleman v. Newsom), ruled that the CDCR violated the cruel and unusual punishment clause of the Constitution by failing to provide adequate mental health care. Since that time, there have been additional orders from the Court requiring changes including, but not limited to, screening, treatment programs, staffing, accurate and complete records, suicide prevention, use of force and medication distribution. These enhancements have all contributed positively to CDCR’s delivery of mental health services, although they come at a substantial cost.
According to CDCR’s Office of Legal Affairs, Class Action Capital Outlay Annual Legislative Report (Fiscal Year 22/23), during Fiscal Year (FY) 22/23, CDCR expended a total of $23,618,109.00 in direct costs related to the Coleman v. Newsom class action. [2] This is a significant amount of money taken from CDCR’s budget to cover defense litigation, fees and costs paid to the plaintiffs’ counsel, defense experts and the court for disbursement to the court-appointed Special Master’s team.

The difficulty in managing the safety of all involved becomes more pronounced in cases involving dual diagnoses. Dual diagnoses involving substance use and mental illness have contributed to a trend reflecting an ongoing struggle to balance incarcerated person rights with the need for safety and management of disruptive behaviors in correctional facilities, while adding complexity to the administration of involuntary medication. [3] Additionally, although CDCR staff are well trained on responding to emergencies and their use of force policies, it is suggested that emergency situations are broadly defined by some correctional staff, allowing them to utilize force or medication under questionable circumstances, and there is a fear of inappropriate use of physical force and medication as a form of control rather than a medically necessary intervention [4].

Although the issue of medicating those under the care of CDCR is complex, there is hope. CDCR could become more effective with far less trauma, and also save millions of dollars in litigation-related costs associated with the mental health care of incarcerated persons and work-related injuries to staff by considering the use of biotechnical administration of medication.

Where we are now, and what is lacking

Supreme Court case Harper v. Washington (1990) established the legal framework for involuntary medication in correctional settings, allowing the forced administration of antipsychotic drugs to incarcerated persons deemed a danger to themselves or others. [5] This ruling has continued to shape California’s policies over the past decades, forming the foundation for how involuntary medication is justified. CDCR is authorized by PC section 2602 to seek a court order from an Administrative Law Judge authorizing the administration of involuntary antipsychotic medication to individuals confined under their jurisdiction who, because of mental disorders, are a danger to others, themselves or are gravely disabled. [6] This legal framework seeks to balance the necessity of treating incarcerated persons with severe mental health issues and the protection of their constitutional rights.

While it is imperative to ensure incarcerated persons receive necessary medical treatment, the use of force can extend complexities for correctional/healthcare staff, the incarcerated population and the overall mission/vision of CDCR. Despite the legal safeguards in place, the CDCR continues to face challenges in implementing involuntary medication protocols.

The use of force can exacerbate distrust in medical and correctional staff, leading to adverse psychological and emotional impacts on the incarcerated persons, including but not limited to increased psychological trauma, particularly for individuals with mental health conditions. As a result of trauma endured from experiencing and witnessing the use of force, rehabilitative efforts may be hindered and resistance to further treatment heightened. The perception of medication as a punitive measure rather than a therapeutic intervention can deter individuals from engaging in necessary medical treatment. Incarcerated persons subjected to forced medication may become more resistant to future voluntary treatment, making long-term rehabilitation more challenging. Additionally, it has been suggested that trauma experienced while incarcerated can lead to Post-Incarceration Syndrome and high rates of Potentially Traumatic Events. [7]

According to the CDCR Office of Research, between January 2020 and December 2024, CDCR averaged approximately 6,165 use-of-force incidents involving incarcerated persons under a Mental Health Services Delivery System (MHSDS) Level of Care (LOC). As of February 2025, there have been 1,338 incidents requiring the use of force involving incarcerated persons under a MHSDS LOC, many of which necessitated the demand for forced or involuntary administration of medication.

Considering the number of incidents related to the application of court-ordered medications, the integration of biotechnical pharmaceutical administration in correctional facilities could greatly impact the future of medication administration in correctional facilities and lead to a shift in policing strategies nationwide.

The biotechnical administration of pharmaceuticals

The use of biotechnical advancements such as Implantable Drug Delivery Systems (IDDS) could greatly impact the future of medication administration in correctional facilities, as medication compliance contributes to an overall safer environment. The IDDS is a medical device that can be surgically placed inside patient tissues to introduce a therapeutic substance and improve its efficacy and safety by controlling the rate, time and place of drug release in the body. [8] This results in minimal reliance on the use of physical force to administer medication, an outcome that would reduce trauma, recidivism, use-of-force incidents, staff assaults and suicides if used in correctional settings.

How to get there, and what can be done

Currently, IDDSs are not widely used in correctional facilities. These systems are primarily utilized in medical settings to manage chronic conditions such as pain, cancer and neurological disorders, by providing targeted and controlled release of medications. [9] While the ethical implications of forcibly medicating individuals, along with legal mandates and logistical challenges of ensuring compliance in a secure and often challenging environment, make this a critical issue for correctional facilities to ensure the rights of the incarcerated are protected, transitioning to the biotechnical administration of pharmaceuticals in California correctional facilities could enhance safety, medication compliance and accuracy while reducing confrontational interactions.

To accomplish this transition, CDCR should establish a multidisciplinary workgroup of medical, mental health and correctional personnel to develop a strategic implementation plan. This team would tackle ethical concerns (involuntary medication, privacy, bodily autonomy) and legal requirements, updating policies to ensure compliance with ethical and regulatory standards. Developing comprehensive policies that reflect and clearly define the procedures for utilizing biotechnology in medication administration would be essential in this plan.

Although related costs could total several millions of dollars, the Governor’s 2024–2025 Budget allocated $140 million from the General Fund for CDCR to train staff, making education a priority investment. Training correctional and medical staff, while educating incarcerated persons on medication benefits, may improve voluntary compliance and informed decision-making. Additionally, this would include training for appropriate medical personnel on the installation and monitoring of IDDSs. This training would be an investment well worth any associated costs, and the integration could contribute to more humane policing and lower incarceration rates, ultimately altering the role of law enforcement in public health and safety as well as the rehabilitation of those incarcerated.

Enhanced informed consent practices such as clear communication of risks, benefits and alternatives are advantageous in addressing the ethical implications of the Food and Drug Administration’s (FDA) evolving approval standards for drugs and medical devices [10]. Educating the staff and incarcerated population, coupled with transparency, fosters a supportive atmosphere conducive to rehabilitation and helps build trust between all.

Imagine a world in which California correctional facilities achieve a balance between biotechnological innovation and human oversight in administering court-ordered medications. A place where smart implants and artificial intelligence systems are used selectively and in combination with real-time monitoring by medical personnel, ensuring accurate and humane treatment for incarcerated persons — potentially your family, friends and loved ones. This equilibrium represents a stable, sustainable approach where technology enhances but does not replace human judgment.

Correctional facilities are increasingly adopting technological tools such as electronic health records and barcode medication administration systems. These technologies have proven to reduce errors and improve the safety and tracking of involuntary medication administration. Adopting the biotechnical administration of pharmaceuticals could further improve the California Healthcare Model, save lives and support CDCR’s goals within the California Model and rehabilitative efforts.

Conclusion

Healthcare comes with a high price in correctional facilities. Biotechnical administration of medication could free up correctional and medical staff to tend to other critical tasks. Additionally, involuntary medication consumes significant resources, which could be better utilized. Biotechnical-assisted medication could streamline processes, improve mental health outcomes and shift mental health crises from correctional to healthcare facilities, enhancing rehabilitation and public safety and reshaping traditional law enforcement efforts. Ralph Diaz, a previous Secretary of CDCR, said, “today’s inmate is tomorrow’s neighbor” during a tour of the Ohio Lucasville Correctional Facility in 2013. [11] This is a powerful statement as we consider the efforts placed on rehabilitation and community reintegration. Remember, Bobo is today’s incarcerated person but could be tomorrow’s neighbor!

References

1. Lyons B, Wiener J. Inmate shuffle: California bounces around its mentally ill prisoners. CalMatters. June 2, 2022.
2. California Department of Corrections and Rehabilitation, Office of Legal Affairs. Class Action Capital Outlay Annual Legislative Report, Fiscal Year 22/23. 2023.
3. Salazar R. Improving medication administration safety in a correctional facility with an electronic medication administration system [master’s project]. San Francisco, CA: University of San Francisco; 2021.
4. Orta J, Baeton C, Llao P, et al. A review of policies on the involuntary use of psychotropic medications among persons experiencing incarceration in the United States. Health Justice. 2023;11(9).
5. Washington v. Harper, 494 US 210 (1990).
6. California Penal Code § 2602. Effective January 1, 2023.
7. Quandt K, Jones A. Research roundup: Incarceration can cause lasting damage to mental health. Prison Policy Initiative. May 13, 2021.
8. Fayzullin A, Bakulina A, Mikaelyan K, Shekhter A, Guller A. Implantable drug delivery systems and foreign body reaction: Traversing the current clinical landscape. Bioengineering. 2021;8:205.
9. Osenbach RK, Burchiel KJ. Implantable drug delivery systems. In: Salcman M, ed. Current Techniques in Neurosurgery. New York, NY: Springer; 1998.
10. Darrow JJ, Dhruva SS, Redberg RF. Changing FDA approval standards: Ethical implications for patient consent. J Gen Intern Med. 2021;36(10):3212–3214.
11. Secretary’s Corner. Secretary Diaz retires, reflects on three decades of public service. CDCR Inside CDCR. September 30, 2020.

About the author

Yesha Hill is a dedicated Correctional Administrator with the California Department of Corrections and Rehabilitation (CDCR), with nearly 18 years of experience including custody operations, correctional counseling, institutional leadership and rehabilitative programming under various CDCR missions. With a career spanning from Correctional Officer to acting Chief Deputy Warden, she has been instrumental in developing and overseeing programs, departmental policies and procedures that enhance institutional safety and security while fostering rehabilitative initiatives and successful community reentry for incarcerated persons.

Rising through the ranks as Correctional Officer, Correctional Sergeant, Correctional Counselor I, II & III, Correctional Captain, Associate Warden, and now acting Chief Deputy Warden, Hill has had oversight and responsibility of staff training and development, program implementation, access to medical, mental health, dental, educational and vocational programs, case management, classification, and rehabilitative programming for the incarcerated population. She has worked closely with male and female incarcerated individuals of all levels of care to develop personalized pathways toward rehabilitation and played a crucial role in implementing and managing evidence-based behavioral intervention, cognitive-behavioral therapy (CBT) and Substance Use Disorder Treatment programs that align with CDCR’s mission.

Hill holds a degree in Psychology from California State University, Fresno and has completed advanced training in correctional leadership, emergency management, and rehabilitative programming through CDCR’s Executive Development programs. She is committed to staff mentorship, policy development, community reentry efforts and enhancing institutional, staff and public safety.She values family and keeping God at the forefront!

This article is based on research conducted as a part of the CA POST Command College. It is a futures study of a particular emerging issue of relevance to law enforcement. Its purpose is not to predict the future; rather, to project a variety of possible scenarios useful for planning and action in anticipation of the emerging landscape facing policing organizations.

The article was created using the futures forecasting process of Command College and its outcomes. Managing the future means influencing it — creating, constraining and adapting to emerging trends and events in a way that optimizes the opportunities and minimizes the threats of relevance to the profession.