Medina v. California (1992)

United States Supreme Court

505 U.S. 437

Nature of Case

Whether it is unconstitutional, according to due process rights, to assume the defendant is competent and to place the burden of proving incompetence on the defendant.

Facts of Case

Teofilo Medina, Jr. stole a gun from a pawnshop in Santa Ana, California and then robbed a market, a drive-in dairy, and two gas stations. He also murdered three employees, attempted to rob a fourth employee, and shot at two individuals who tried to follow his car. He was caught and arrested within one month of these crimes and he was charged with multiple offenses, including three counts of first-degree murder. The defendant’s attorney requested a competency hearing. The trial court granted the motion for a competency hearing, which was tried to a jury over the course of six days and included conflicting expert testimony. The jury received instructions that “the defendant is presumed to be mentally competent and he has the burden of proving by a preponderance of the evidence that he is mentally incompetent as a result of mental disorder or developmental disability.” The jury found the defendant competent to stand trial. The defendant was found guilty on all three counts of first-degree murder and the death penalty was imposed.

Upon writ of certiorari to the Supreme Court of California, the defendant’s conviction and sentence were upheld and the defendant’s claims of due process violations were rejected. The petitioner sought review of the California Supreme Court decision and the United States Supreme Court granted cert.

Issue

Did the California Supreme Court err in rejecting the petitioner’s contentions that it is unconstitutional to assume competency and to place the burden of proving incompetence on the defendant?

Holding

In a 7 to 2 decision, the Court affirmed the decision of the California Supreme Court.

They held that the Due Process Clause of the Fourteenth Amendment allows states to presume competence and to allow the burden of proving incompetence to be placed on the party raising the question of competency. The Court recognized that “although an impaired defendant might be limited in his or her ability to assist counsel in demonstrating incompetence, such inability can itself constitute probative evidence of incompetence.” The Court also stated that the defense counsel often has the “best-informed view of the defendant’s ability to participate.” The Court affirmed the preponderance of the evidence standard was sufficient to meet due process requirements.

Rationale

The Court concluded that due process only requires “the most basic procedural safeguards” and once the defendant is provided “access to procedures for making a competency evaluation,” due process does not further require “the state to assume the burden” of proving competency. The Court stated that this “does not offend a principle of justice so rooted in the traditions and conscience of the American people as to be ranked as fundamental.” The Court further stated that the burden of proof being placed on the defendant would only be an issue in a “narrow class of cases” when the evidence was equal regarding competence and incompetence.

Dissenting opinion

Justice Blackmun, joined by Justice Stevens dissented on the grounds that the burden of proof should be placed on the prosecution in order to protect the due process rights of the defendant to be tried only when competent. Furthermore, the Justices stated that when the defendant is housed for treatment or evaluated in a State facility, the State may have better evidence of the defendant’s mental health than the defense counsel.