What is the test for determining whether a defendant is competent to stand trial on medication?

The only question preserved for appeal is whether the court should have postponed appellant's afternoon testimony when defense counsel requested a recess so that appellant could take his medication. That was the only request made in the trial court. This case did not involve the denial of appellant's right to testify as he states on appeal. Appellant was given the opportunity to testify, chose to exercise it, and testified at length. Nor does this case involve the forced medication of a prisoner as in Riggins v. Nevada (1992) 504 U.S. 127, the case principally relied on by appellant. Riggins concerned forcing a defendant to take medication, which produced side effects hampering cross-examination, interaction with counsel, or comprehension of trial despite no finding that the medication was medically appropriate or essential for the defendant's safety or the safety of others and may have denied the defendant a full and fair trial. (See id. at pp. 133-138.) Riggins is not relevant here because the state did not force appellant to take medication. Finally, this case does not require evaluating whether a competency hearing was required because appellant "does not contend that the trial court should have held a full competency hearing accompanied by a formal psychiatric evaluation and jury trial."

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