What is the test for a prison to forcibly medicate an inmate with an antipsychotic drug?

The decision to forcibly medicate an inmate implicates both substantive and procedural due process. Washington v. Harper, 494 U.S. 210, 222, 110 S.Ct. 1028, 1036 (1990). Inmates have "a significant liberty interest in avoiding the unwanted administration of antipsychotic drugs under the Due Process Clause of the Fourteenth Amendment." U.S. v. Loughner, 672 F.3d 731, 744 (9th Cir. 2012) (quoting Washington, 494 U.S. at 221-22). However, the liberty interest "must be 'defined in the context of the inmate's confinement.'" Loughner, 672 F.3d at 745 (quoting Washington, 494 U.S. at 222). Prison officials have an obligation to provide prisoners with medical treatment and have a duty to take reasonable measures to ensure an inmate's safety. Washington, 494 U.S. at 225.