Whether the State of New Jersey's administration of unreasonably high doses of the controlled psychotropic drug Xanax violated the defendant's constitutional rights

QUESTIONS PRESENTED 1. Whether the State of New Jersey's administration of unreasonably high doses of the controlled psychotropic drug Xanax (i.e., dosages four times the manufacturer’s recommended starting dose) to Petitioner Donald E. Boyd while representing himself during his criminal trial violated his constitutional rights to counsel, a fair trial and due process? 2. Whether the State of New Jersey violated Petitioner Donald E. Boyd’s Sixth Amendment right to counsel by failing to consider the intervening change in circumstances in drugging him with unreasonably high doses of a controlled psychotropic drug, rendering his prior Faretta waiver no longer knowing, voluntary and intelligent at the time it was made one month earlier? 3. Whether it is unconstitutional for a state to prescribe and administer powerful doses of a controlled psychotropic drug to a criminal defendant acting as his own attorney during his criminal trial without an in-person or face-to-face evaluation by a prescribing physician or other medical professional? i PARTIES The only parties to this proceeding are identified in the case caption on the cover. ii STATEMENT OF RELATED CASES e Petition for Post-Conviction Relief o State v. Boyd, Indictment No. 04-06-1142, Superior Court of New Jersey, Law Division, Bergen County. Petition for post-conviction relief denied on October 11, 2013. o State v. Boyd. Affirmed by New Jersey Superior Court, Appellate Division, A-2171-13T1 (N.J. Super. Ct. App. Div., Sept. 30, 2016). o State v. Boyd. Certification denied by New Jersey Supreme Court, 078465, C-645 Sept. Term 2016 (Mar. 16, 2017). e Civil Claim (42 U.S.C. § 1983) o Boyd v. Bergen County Jail, Civ. Case No. 07-769 (FSH) (PS) (D.N.J.). Partial summary judgment entered by the United States District Court for the District of New Jersey (Sept. 4, 2012). o Boyd v. Bergen County Jail. Affirmed sub nom. by the Third Circuit Court of Appeals, Boyd v. Russo, No, 13-1521 (Aug. 27, 2013). Case settled for monetary amount. e Direct Criminal Appeal o State v. Boyd, Indictment No. 04-06-1142, Superior Court of New Jersey, Law Division, Bergen County. Judgment entered June 27, 2006. o State v. Boyd. Remanded for resentencing by New Jersey Superior Court, Appellate Division, A-6537-05T4 (N.J. Super. App. Div. Aug. 12, 2008). o State v. Boyd. Certification denied by New Jersey Supreme Court, Nos. C-410 Sept. Term 2008, 63,165, 197 N.J. 16. (Nov. 19, 2008). o State v. Boyd. Certiorari denied by United States Supreme Court, No. 08-9145, 129 S. Ct. 2391 (May 18, 2009). o State v. Boyd. Change of Judgment entered December 1, 2008. Affirmed by New Jersey Superior Court, Appellate Division, A-005315-08T4 (Mar. 7, 2010). iii