Whether a district court must specifically address substantial evidence undermining the case for forcible medication of a criminal defendant to restore competence under Sell v. United States

When ordering that a criminal defendant be forcibl y medicat ed to restore competence under Sell v. United States, 539 U.S. 166 (2003) , must a district court specifically contend with substantial evidence that would undermine the case for forcible medication , as the Fourth Circuit requires in United States v. Watson , 793 F.3d 416 (4th Cir. 2015), or can a court order forcible medication without even addressing such evidence, as the Tenth Circuit permit ted below ?