Peo in Interest of McNair

CourtColorado Court of Appeals
DecidedAugust 14, 2025
Docket25CA0840
StatusUnpublished

This text of Peo in Interest of McNair (Peo in Interest of McNair) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peo in Interest of McNair, (Colo. Ct. App. 2025).

Opinion

25CA0840 Peo in Interest of McNair 08-14-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA0840 Pueblo County District Court No. 25MH30036 Honorable Amiel Markenson, Judge

The People of the State of Colorado,

Petitioner-Appellee,

In the Interest of Lonny Lynn McNair,

Respondent-Appellant.

ORDER AFFIRMED

Division IV Opinion by JUDGE MEIRINK Freyre and Gomez, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced August 14, 2025

Cynthia Mitchell, County Attorney, Kate H. Shafer, Special Assistant County Attorney, Pueblo, Colorado, for Petitioner-Appellee

Tezak Law, P.C., Mary Tezak, Florence, Colorado, for Respondent-Appellant ¶1 Lonny Lynn McNair appeals the district court’s order

authorizing the involuntary administration of an antipsychotic

medication for the purpose of restoring him to competency to stand

trial in a criminal case. We affirm.

I. Background

¶2 In Adams County District Court case number 20CR2735,

McNair was charged with numerous serious crimes, including class

1 felonies.

¶3 After being found incompetent to proceed in that case, McNair

was admitted to the Colorado Mental Health Hospital in Pueblo (the

hospital) in September 2024 to restore his competency. McNair’s

psychiatrist at the hospital diagnosed him with delusional disorder,

persecutory type. His primary, consistent symptom has been

having prominent persecutory delusions that he is being targeted

and surveilled by a secret, expansive, and sophisticated network of

people. His delusions include believing that this network of people

“take[] over” his phone, leading him to destroy the phone and get a

new phone every month; that people in the network tried to poison

him; and that strangers he meets are involved in the network.

1 ¶4 In March 2025, McNair was again found incompetent to

proceed. In April, the State filed a petition for authorization to

medicate McNair involuntarily with aripiprazole (Abilify), olanzapine

(Zyprexa), and paliperidone (Invega).

¶5 At the hearing on the petition, McNair’s psychiatrist at the

hospital and McNair both testified. The psychiatrist, an expert in

clinical psychiatry, testified that McNair’s delusional disorder

constitutes a substantial disorder that grossly impairs his judgment

or capacity to recognize reality or control behavior. The psychiatrist

also testified that antipsychotic medication is necessary to improve

McNair’s delusional disorder, and that without the medication, he

will not be restored to competency.

¶6 The psychiatrist clarified that he was no longer seeking to

treat McNair with paliperidone, but that he was requesting

authorization to treat him with aripiprazole and olanzapine. He

testified that he planned to initially treat McNair with only

aripiprazole, and that if McNair did not adequately respond to

treatment with that medication, he would instead treat McNair with

olanzapine. The psychiatrist also reported that McNair does not

2 believe he has delusional disorder, does not believe he needs any

antipsychotic medication, and will not take medication voluntarily.

¶7 During McNair’s testimony, he testified that he does not have

a delusional disorder, or any other mental illness, and does not

want to take medication. He also testified at length about the

network of people targeting and surveilling him.

¶8 Following the testimony, the district court found that the

psychiatrist had testified credibly and persuasively, and it adopted

the psychiatrist’s opinions. As to olanzapine, the court found that

the People had not met their burden of proving the need to use that

backup medication. However, as to aripiprazole, the court granted

the petition, finding that the People had met their burden of proving

all four elements of the test from Sell v. United States, 539 U.S. 166,

180-81 (2003).

II. Applicable Law

¶9 The parties agree that the four-part test from Sell applies here.

Under that test, the State must prove that:

(1) “important governmental interests” — such as “bringing

to trial an individual accused of a serious crime” — are at

stake,

3 (2) involuntarily medicating the person will “significantly

further” those interests,

(3) involuntarily medicating the person is “necessary” to

further those interests, and

(4) administering the medication to the person is “medically

appropriate,” in other words, “in the patient’s best

medical interest in light of his medical condition.”

Id. (emphasis omitted).

¶ 10 The State must prove these elements by clear and convincing

evidence. People in Interest of Joergensen, 2022 COA 126, ¶ 12;

People in Interest of R.F., 2019 COA 110, ¶ 16. A physician’s

testimony alone may constitute clear and convincing evidence. See

People v. Pflugbeil, 834 P.2d 843, 846-47 (Colo. App. 1992).

III. Analysis

¶ 11 McNair does not contest the district court’s rulings that the

People met their burden of proving the first, second, and third

elements of the Sell test. However, he challenges the sufficiency of

the evidence supporting the fourth Sell element — that treating him

with aripiprazole is “medically appropriate.”

4 ¶ 12 In determining whether the evidence was sufficient to support

an involuntary medication order, we view the evidence as a whole

and in the light most favorable to the prevailing party. See People in

Interest of R.K.L., 2016 COA 84, ¶ 13.

¶ 13 A district court’s findings with respect to the fourth Sell

element are factual in nature and are therefore subject to review for

clear error. R.F., ¶ 21; People in Interest of Hardesty, 2014 COA

138, ¶ 17. We defer to findings of fact that are supported by

evidence in the record. People in Interest of Ramsey, 2023 COA 95,

¶ 23. We also defer to a district court’s credibility determinations

and its weighing of conflicting evidence. Id. at ¶ 30.

¶ 14 Here, the district court found that treating McNair with

aripiprazole was medically appropriate. It expressly based its

finding on “everything [the psychiatrist] has already testified to,”

which it found to be “very credible.”

¶ 15 The district court’s finding is supported by the psychiatrist’s

testimony that treating McNair with antipsychotic medication was

“medically appropriate” and was in McNair’s “best medical interest,”

given his mental condition. Specifically, the psychiatrist testified

that there is a “substantial likelihood” that treating McNair with

5 antipsychotic medication would improve his delusional disorder,

aripiprazole is particularly effective in treating delusional disorders,

and there was no alternative treatment that would work as

effectively as antipsychotic medication. The psychiatrist also

testified that (1) McNair would be regularly monitored for any side

effects that aripiprazole might cause; (2) the risk is “extremely low”

that McNair would experience any side effects that would impair his

ability to assist in his defense in the criminal case; (3) aripiprazole

has a more favorable side effect profile relative to other

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Related

Sell v. United States
539 U.S. 166 (Supreme Court, 2003)
People v. Pflugbeil
834 P.2d 843 (Colorado Court of Appeals, 1992)
People ex rel. R.K.L
2016 COA 84 (Colorado Court of Appeals, 2016)
in Interest of R.F
2019 COA 110 (Colorado Court of Appeals, 2019)

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Peo in Interest of McNair, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peo-in-interest-of-mcnair-coloctapp-2025.