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dangerously high dosages of otherwise safe drugs and would not give defense counsel and experts a meaningful ability to challenge the propriety of the proposed treatment.’ United States v. Evans, 404 F.3d 227, 241 (4 th Cir., 2005). Sell indicates that its test should be applied in the context of a specific proposed treatment plan for a specific defendant. See 539 U.S. at 183 (stating that the ultimate question for the trial court is, ‘Has the Government, in light of the efficacy, the side effects, the possible alternatives, and the medical appropriateness of a particular course of antipsychotic drug treatment, shown a need for that treatment sufficiently important to overcome the individual’s protected interest in refusing it?’ (emphasis added; citations omitted)). Accordingly, as many other courts have held, we now hold that the Sell test can be properly applied only in relation to an individualized treatment plan that specifies, at a minimum, (1) the drug or drugs the treating physicians are permitted to use on the defendant, (2) the maximum dosages that may be administered, and (3) the duration the drugs may be used before the physicians report back to the court.” Courts may, however, “‘properly approve treatment plans identifying a range of medications that could be used if the first drug or drugs administered prove unsatisfactory. We also note that either the government or the defendant may move to revise the court’s Sell order if circumstances change during a defendant’s treatment,’” quoting United States v. Chavez, 734 F.3d 1247, 1254 (10 th Cir., 2013)” United States v. Chavez, 734 F.3d 1247, 1252 (10th Cir.2013). 4. Order fails to consider whether less intrusive means are available, such as simply ordering defendant on paid of contempt to comply with treatment. Especially relevant here, where the evidence is in conflict as to whether defendant has ever refused to take prescribed medication in the past. Court should also consider ordering involuntary medication for other purposes “‘such as the purposes set out in Harper related to the individual’s dangerousness, or purposes related to the individual’s own interests where the refusal to take drugs puts his health gravely at risk.’ Sell, 539 U.S. at 182 (emphasis in original) (referring to Washington v. Harper, 494 U.S. 210, 110 S.Ct. 1028, 108 L.Ed.2d 178 (1990)).” “‘The medical experts may find it easier to provide an informed opinion about whether, given the risk of side effects, particular drugs are medically appropriate and necessary to control a patient’s potentially dangerous behavior (or to avoid serious harm to the patient himself) than to try to balance harms and benefits related to the more quintessentially legal questions of trial fairness and competence.’ Id. at 182 (citation omitted).” Sell v. United States, 539 U.S. 166, 123 S.Ct. 2174, 156 L.Ed.2d 197 (June 16, 2003). Government sought, and defendant opposed, pre-trial order authorizing involuntary administration of anti-psychotic drugs for two purposes: because defendant posed a threat to himself and others while in a federal institution receiving treatment and awaiting trial; and to restore him to competency to stand trial. Magistrate approved administration of the drugs on both grounds, but district court and court of appeals upheld only based on need to restore to competency to stand trial. Supreme Court agrees that the involuntary administration of drugs to an individual accused of a crime to make him competent to stand trial does not violate that individual’s Fifth Amendment “liberty” rights if made pursuant to a court’s determination that: 1) there is an “important governmental interest” at stake, such as the need to bring an accused to trial; however, “special circumstances,” such as confinement in a mental institution, thus reducing the risks to others, “may lessen the importance of that interest;” 2) “the court must conclude that involuntary medication will significantly further those concomitant state interests;” 3) “the court must conclude that involuntary medication is necessary to further those interests,” that is, “less intrusive treatments are unlikely to achieve substantially the same results;” and 4) “the court must conclude that administration of the drugs is medically appropriate, i.e., in the patient’s best medical interest in light of his medical condition.” (Emphasis in original.) The Court notes that this analysis is unnecessary if trial court finds that the medication is needed because of the individual’s dangerousness or “where refusal to take drugs puts his health gravely at risk.” Remanded for application of this determination. Based on Washington v. Harper , 494 U.S. 210, 110 S.Ct. 1028, 108 L.Ed.2d 178 (1990) (“the Due Process Clause permits the State to treat a prison inmate who has a serious mental illness with antipsychotic drugs against his will, if the inmate is dangerous to himself or others and the treatment is in the inmate’s medical interest.”) and Riggins v. Nevada , 504 U.S. 127, 112 S.Ct. 1810, 118 L.Ed.2d 479 (1992) (although forced medication to render a defendant competent to stand trial may be constitutionally permissible, thus overcoming defendant’s liberty interest in avoiding involuntary medication, conviction overturned due to failure to prove that treatment was medically appropriate, that there were no less intrusive alternatives, and needed either for safety of self or others or to obtain an adjudication on pending criminal charges). K. CONDUCT OF TRIAL, GENERALLY Ezebuiro v. State, 308 Ga.App. 282, 707 S.E.2d 182 (March 8, 2011). Conviction for robbery by intimidation affirmed; no abuse of discretion where trial court allowed victim to testify while seated on hospital gurney. “Ezebuiro timely objected, claiming that the sight of the victim on a gurney would generate improper sympathy for the victim, perhaps imply that the condition of the victim was worsening, and in any event, prejudice Ezebuiro. The trial court overruled this objection, but it offered to explain to the jury why the victim was seated on a gurney, instead of her wheelchair. Ezebuiro objected, however, to the trial court giving the jury any such explanation.” “It is well-settled that a trial court is vested