order to render that defendant competent to stand trial. The Court held that the defendant has a “significant constitutionally protected liberty interest” at stake, so the drugs could be administered forcibly “only if the treatment is medically appropriate, is substantially unlikely to have side effects that may undermine the fairness of the trial, and, taking account of less intrusive alternatives, is necessary significantly to further important governmental trial-related interests.” Id. at 178-80, 123 S.Ct. 2174(internal quotation marks omitted). Although the Court’s holding in Sell is specific to the context of forcibly administering medication, the scrutiny employed by the Court to reach that holding is instructive. See Miller v. Gammie, 335 F.3d 889, 900 (9th Cir.2003) (en banc) (<HOLDING>). The Court recognized a “significant” liberty
holding carefully considered supreme court dicta though not binding must be accorded great weight and should be treated as authoritative although the supreme court may ignore its own dicta we are a lower court bound by the supreme court internal citations omitted holding that we are required to predict the position which the pennsylvania supreme court would take in resolving this dispute  and in the absence of a clear statement by the pennsylvania supreme court to the contrary or other persuasive evidence of a change in pennsylvania law we are bound by the holdings of previous panels of this court holding that court is bound by prior panels interpretation of supreme court decision holding that we are bound by the theory or reasoning underlying a supreme court case not just by its holding holding that we are bound by prior panel opinions until they are overruled or abrogated by the supreme court or this court sitting en banc