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90-8370.ZS
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NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
MEDINA v. CALIFORNIA
certiorari to the supreme court of california
No. 90-8370. Argued February 25, 1992-Decided June 22, 1992
Before petitioner Medina's trial for, inter alia, first-degree murder, the
California court granted his motion for a competency hearing pursu-
ant to a state law that forbids a mentally incompetent person to be
tried or punished, establishes a presumption of competence, and
placed on petitioner the burden of proving incompetence by a prepon-
derance of the evidence. The jury empaneled for the competency
hearing found Medina competent to stand trial and, subsequently, he
was convicted and sentenced to death. The State Supreme Court
affirmed, rejecting Medina's claim that the competency statute's
burden of proof and presumption provisions violated his right to due
process.
Held:
1.The Due Process Clause permits a State to require that a
defendant claiming incompetence to stand trial bear the burden of
proving so by a preponderance of the evidence. Pp.4-15.
(a)Contrary to Medina's argument, the Mathews v. Eldridge, 424
U.S. 319, test for evaluating procedural due process claims does not
provide the appropriate framework for assessing the validity of state
procedural rules that are part of the criminal law process. It is not
at all clear that Mathews was essential to the results in United
States v. Raddatz, 447 U.S. 667, or Ake v. Oklahoma, 470 U.S. 68,
the only criminal law cases in which this Court has invoked Mathews
in resolving due process claims. Rather, the proper analytical
approach is that set forth in Patterson v. New York, 432 U.S. 197,
in which this Court held that the power of a State to regulate
procedures for carrying out its criminal laws, including the burdens
of producing evidence and persuasion, is not subject to proscription
under the Due Process Clause unless ```it offends some principle of
justice so rooted in the traditions and conscience of our people as to
be ranked as fundamental.''' Id., at 201-202. Pp.4-7.
(b)There is no historical basis for concluding that allocating the
burden of proof to a criminal defendant to prove incompetence
violates due process. While the rule that an incompetent criminal
defendant should not be required to stand trial has deep roots in this
country's common-law heritage, no settled tradition exists for the
proper allocation of the burden of proof in a competency proceeding.
Moreover, contemporary practice demonstrates that there remains no
settled view on where the burden should lie. Pp.8-10.
(c)Nor does the State's allocation of the burden of proof to a
defendant transgress any recognized principle of ``fundamental
fairness'' in operation. This Court's decision in Leland v. Oregon, 343
U.S. 790-which upheld a State's right to place on a defendant the
burden of proving the defense of insanity-does not compel the
conclusion that the procedural rule at issue is constitutional, because
there are significant differences between a claim of incompetence and
a plea of not guilty by reason of insanity. Nonetheless, once the
State has met its due process obligation of providing a defendant
access to procedures for making a competency evaluation, there is no
basis for requiring it to assume the burden of vindicating the defend-
ant's constitutional right not to be tried while legally incompetent by
persuading the trier of fact that the defendant is competent to stand
trial. Pp.10-11.
(d)Allocating the burden to the defendant is not inconsistent
with this Court's holding in Pate v. Robinson, 383 U.S. 375, 384,
that a defendant whose competence is in doubt cannot be deemed to
have waived his right to a competency hearing, because the question
whether a defendant whose competence is in doubt can be deemed to
have made a knowing and intelligent waiver is quite different from
the question presented here. Although psychiatry is an inexact
science and reasonable minds may differ as to the wisdom of placing
the burden of proof on the defendant in these circumstances, the
State is not required to adopt one procedure over another on the
basis that it may produce results more favorable to the accused. In
addition, the fact that the burden of proof has been allocated to the
State on a variety of other issues implicating a criminal defendant's
constitutional rights does not mean that the burden must be placed
on the State here. Lego v. Twomey, 404 U.S. 477, 489, distin-
guished. Pp.11-14.
2.For the same reasons discussed herein with regard to the
allocation of the burden of proof, the presumption of competence does
not violate due process. There is no reason to disturb the State
Supreme Court's conclusion that, in essence, the challenged presump-
tion is a restatement of that burden. P.14.
51 Cal.3d 870, 799 P.2d 1282, affirmed.
Kennedy, J., delivered the opinion of the Court, in which Rehnquist,
C. J., and White, Scalia, and Thomas, JJ., joined. O'Connor, J., filed
an opinion concurring in the judgment, in which Souter, J., joined.
Blackmun, J., filed a dissenting opinion, in which Stevens, J., joined.