The Hawaii Supreme Court upheld a trial court order to medicate defendant Kotis against his wishes. Kotis maintained that involuntary mediation for psychiatric reasons violated his Constitutional due process rights under both the state and federal Constitutions.

Kotis had been charged with Murder in the second degree, kidnapping, and making terroristic threats in connection with an incident where one person was killed. He was evaluated pursuant to Hawaii statutes and found incompetent to stand trial based on the opinion of three evaluators. The trial court proceeded under the statute to order his care and treatment in an appropriate state institution. The director of the mental health facility requested the court to allow involuntary medication. The Court did so after a hearing at which it made findings based on the record and testimony of evaluating physicians.

The Supreme Court upheld the involuntary medication order because the trial court had found that Kotis 1) actually posed a danger of physical harm to himself or others; 2) that treatment with antipsychotic medication was appropriate and in the defendant's best interest and; 3) that in consideration of less intrusive treatment, this treatment is essential to forestall the danger posed by the defendant.

Kotis had appealed contending that as a prisoner awaiting trial his right not to be medicated was absolute under the Federal Constitution. The Court reviewed the applicable law and found again that the trial court had acted within the law in ordering Kotis medicated.