505 U.S. 437 (1992), 90-8370, Medina v. California

Docket Nº:No. 90-8370
Citation:505 U.S. 437, 112 S.Ct. 2572, 120 L.Ed.2d 353, 60 U.S.L.W. 4684
Party Name:Medina v. California
Case Date:June 22, 1992
Court:United States Supreme Court

Page 437

505 U.S. 437 (1992)

112 S.Ct. 2572, 120 L.Ed.2d 353, 60 U.S.L.W. 4684




No. 90-8370

United States Supreme Court

June 22, 1992

Argued Feb. 25, 1992



Before petitioner Medina's trial for, inter alia, first-degree murder, the California court granted his motion for a competency hearing pursuant 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 preponderance 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.

[112 S.Ct. 2573] 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. 442-453.

(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. 442-446.

(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

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practice demonstrates that there remains no settled view on where the burden should lie. Pp. 446-448.

(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 defendant'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. 448-449.

(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, distinguished. Pp. 449-452.

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 [112 S.Ct. 2574] Supreme Court's conclusion that, in essence, the challenged presumption is a restatement of that burden. PP. 452-453.

51 Cal.3d 870, 274 Cal.Rptr. 849, 799 P.2d 1282 (1990), 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, post, p. 453. BLACKMUN, J., filed a dissenting opinion, in which STEVENS, J., joined, post, p. 456.

Page 439

KENNEDY, J., lead opinion

JUSTICE KENNEDY delivered the opinion of the Court.

It is well established that the Due Process Clause of the Fourteenth Amendment prohibits the criminal prosecution of a defendant who is not competent to stand trial. Drope v. Missouri, 420 U.S. 162 (1975); Pate v. Robinson, 383 U.S. 375 (1966). The issue in this case is whether the Due Process Clause permits a State to require a defendant who alleges incompetence to stand trial to bear the burden of proving so by a preponderance of the evidence.


In 1984, petitioner Teofilo Medina, Jr. stole a gun from a pawn shop in Santa Ana, California. In the weeks that followed, he held up two gas stations, a drive-in dairy, and a market, murdered three employees of those establishments, attempted to rob a fourth employee, and shot at two passersby who attempted to follow his getaway car. Petitioner was apprehended less than one month after his crime spree

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began, and was charged with a number of criminal offenses, including three counts of first-degree murder. Before trial, petitioner's counsel moved for a competency hearing under Cal.Pen.Code Ann. § 1368 (West 1982), on the ground that he was unsure whether petitioner had the ability to participate in the criminal proceedings against him. 1 Record 320.

Under California law, "[a] person cannot be tried or adjudged to punishment while such person is mentally incompetent." Cal.Pen.Code Ann. § 1367 (West 1982). A defendant is mentally incompetent

if, as a result of mental disorder or developmental disability, the defendant is unable to understand the nature of the criminal proceedings or to assist counsel in the conduct of a defense in a rational manner.

Ibid. The statute establishes a presumption that the defendant is competent, and the party claiming incompetence bears the burden of proving that the defendant is incompetent by a preponderance of the evidence. § 1369(f) ("It shall be presumed that the defendant is mentally competent unless it is proved by a preponderance of the evidence that the defendant is mentally incompetent").

The trial court granted the motion for a hearing, and the preliminary issue of petitioner's competence to stand trial was tried to a jury. Over the course of the six-day hearing, in addition to lay testimony, the jury heard conflicting expert testimony about petitioner's mental condition. The Supreme Court of California gives this summary:

Dr. Gold, a psychiatrist who knew defendant while he was in the Arizona prison system, testified that defendant was a paranoid schizophrenic and was incompetent to assist his attorney at trial. Dr. Echeandia, a clinical psychologist at the Orange County jail, doubted the accuracy of the schizophrenia diagnosis, and could not express an opinion on defendant's competence to stand trial. Dr. Sharma, a psychiatrist, likewise expressed doubts regarding the schizophrenia diagnosis, and leaned toward a finding of competence. Dr. Pierce,

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a psychologist, believed defendant was schizophrenic, with impaired memory and hallucinations, but nevertheless was competent to stand trial. Dr. Sakurai, a jail psychiatrist, opined that, although defendant suffered from depression, he was competent, and that he may have been malingering. Dr. Sheffield, who treated defendant for knife wounds he incurred in jail, could give no opinion on the competency issue.

51 Cal.3d 870, 880, 274 Cal.Rptr. 849, 855, 799 P.2d 1282, 1288 (1990). During the competency hearing, petitioner engaged in several verbal and physical outbursts. App. 62, 81-82; 3 Record 671, 699, 916. On one of these occasions, he overturned the counsel table. App. 81-82.

The trial court instructed the jury, in accordance with § 1369(f), 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.

App. 87. The jury found petitioner competent to stand trial. Id. at 89. A new jury was impanelled for the criminal trial, 4 Record 1020, and petitioner entered pleas of not guilty and not guilty by reason of insanity. 51 Cal.3d at 899, 274 Cal.Rptr. at 867, 799 P.2d at 1300. At the conclusion of the guilt phase, petitioner was found guilty of all three counts of first-degree murder and a number of lesser offenses. Id. at 878-879, 274 Cal.Rptr. at 854, 799 P.2d at 1287. He moved to withdraw his insanity plea, and the trial court granted the motion. Two days later, however, petitioner moved to reinstate his insanity plea. Although his counsel expressed the view that...

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