Does a defendant who overdoses on a drug during the course of his trial have waived his right to be present at trial?

8 Accordingly, we need not and do not reach the merits of the question of whether a defendant who voluntarily overdoses on a drug in an apparent suicide attempt during the course of his trial must be deemed to have waived his right to be present at trial. But see United States v. Latham, 874 F.2d 852, 858 (1st Cir.1989) (voluntary ingestion of drug was not "voluntary" in same sense as voluntary waiver of rights) (cited favorably by this court in United States v. Houtchens, 926 F.2d at 828, as example of when absence from trial is not voluntary).