KIE: Force feeding of hunger-striking prisoners is discussed in the context of three 1982 state appellate court decisions involving the right to refuse treatment. The Supreme Court of Georgia accepted a prisoner's argument; courts in New York and West Virginia found a compelling state interest that justified force feeding, as did an earlier Massachusetts decision that rejected a prisoner's refusal of renal dialysis. The author contends that the Georgia court erred in not distinguishing the motivation of the prisoner--to manipulate the prison system--from that of patients who refuse treatment.