Supreme Court of the United States · 1992 · Administrative Law
Due ProcessCompetency to Stand TrialBurden of Proof in Criminal ProcedureDue Process Clausecompetency to stand trialburden of proofpresumption of competencePatterson v. New York
Facts
Before trial on multiple murder and robbery charges, Medina's counsel requested a competency hearing under California law. California law barred trial of a mentally incompetent defendant, but presumed competence and required the party claiming incompetence to prove it by a preponderance of the evidence. At the six-day competency hearing, experts gave conflicting testimony about Medina's mental condition, and Medina also engaged in several courtroom outbursts. The jury was instructed that Medina was presumed competent and had the burden of proving incompetence, and it found him competent to stand trial.
Issue
Does the Due Process Clause of the Fourteenth Amendment forbid a State from requiring a criminal defendant who alleges incompetence to stand trial to prove that incompetence by a preponderance of the evidence? Does due process also forbid a presumption of competence at the competency hearing?
Rule
A state rule allocating to the criminal defendant the burden of proving incompetence to stand trial by a preponderance of the evidence does not violate due process unless it offends a principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental. Once the State provides adequate procedures for making a competency evaluation, due process does not require the State to bear the burden of persuading the factfinder that the defendant is competent, and a presumption of competence that functions as a restatement of that burden likewise does not violate due process.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Ohio, Nolan Pierce is charged with felony assault. State law provides that if competency to stand trial is contested, the defendant must prove incompetence by a preponderance of the evidence at a hearing with counsel and court-appointed mental health experts. Nolan argues the statute violates due process because the court should weigh the private interest, risk of error, and state burden under a civil-style balancing test.
Which is the strongest response to Nolan's due process argument?
Explanation. For a due process challenge to a state procedural rule that is part of the criminal process, the governing approach is the more deferential fundamental-fairness inquiry associated with Patterson, not ordinary Mathews balancing. The question is whether the state rule offends a principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental. Medina rejected use of Mathews as the proper framework for this type of challenge.