When ordering that a criminal defendant be forcibly medicated 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 permitted below?

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