United States v. Valenzuela-Puentes, ___ F.3d ___ (10th Cir. March 15, 2007) (court order allowing involuntary medication of illegal reentry defendant so as to render him competent to stand trial is reversed where record did not contain evidence from which a conclusion of a substantial likelihood of restoring competency was unavoidable, the district court provided no explanation as to whether or why it had become clearly convinced that defendant could be rendered competent through medication despite his exceptionally low IQ, and it was unclear whether the district court applied the appropriate burden of proof).
http://laws.lp.findlaw.com/10th/042283.html