As a third consideration, the medication to be administered must be necessary to bring the defendant to trial. That means that nonmedical treatments, per a suggestion in the brief of the American Psychological Association, must be shown to be unlikely to be effective (9). (Read fairly, however, the studies cited in the brief do not indicate that the psychoeducational interventions referred to can substitute for pharmacologic treatment of psychotic symptoms, only that they may have some adjunctive benefit for defendants whose symptoms are otherwise being brought under control with medication.) In addition, and rather astonishingly, Breyer indicated that "the court must consider less intrusive means for administering the drugs, e.g., a court order to the defendant backed by the contempt power, before considering more intrusive methods." For a justice of the U.S. Supreme Court to suggest that a psychotic, treatment-refusing defendant, found incompetent to stand trial and already confined in a prison medical facility would agree to take medication because a judge threatened to hold him in contempt bespeaks a remarkably optimistic view of judicial power—and a serious lack of appreciation of the nature of psychosis.