## Facts

- José Luis Medina was charged in California with serious crimes, including first-degree murder, and later sentenced to death.
- Before trial, Medina sought a determination of competency to stand trial under California law.
- California’s statutory scheme barred trying or punishing a mentally incompetent person, presumed defendants competent, and required the defendant to prove incompetence by a preponderance of the evidence.
- A jury convened solely for a competency hearing found Medina competent.
- Medina was then tried, convicted (including first-degree murder), and sentenced to death.

## Issues

1. Whether the Due Process Clause of the Fourteenth Amendment permits a state to require a defendant asserting incompetence to stand trial to prove incompetence by a preponderance of the evidence.
2. Whether the constitutionality of burden allocation in competency proceedings should be evaluated under a Mathews v. Eldridge balancing approach or a history-and-fundamentals approach associated with Patterson v. New York.

## Decision

- The Supreme Court affirmed, holding that due process permits a state to require a defendant to prove incompetence to stand trial by a preponderance of the evidence.
- The Court declined to treat Mathews v. Eldridge as the general framework for criminal procedural due process challenges to burden allocation.
- Applying a Patterson-style inquiry, the Court found no historically settled rule requiring the State to bear the burden in competency proceedings.
- The Court concluded California’s allocation did not violate basic fairness, given the State’s prohibition on trying the incompetent and the availability of a competency hearing using a preponderance standard.
- Justice Blackmun dissented (Justice Stevens joined in part), arguing the burden should rest on the State because the risk of trying an incompetent defendant is too serious.

## Legal Principles

- A state may presume a criminal defendant competent to stand trial and place on the defendant the burden to prove incompetence by a preponderance of the evidence without violating the Fourteenth Amendment.
- In assessing state criminal procedure rules allocating burdens of proof, due process is violated only if the rule offends a fundamental principle of justice rooted in the nation’s traditions and conscience.
- The mere risk of error in a competency determination does not, by itself, require the State to carry the burden, so long as the overall procedure remains fair and the defendant receives a competency hearing when the issue is raised.

## Conclusion

The Court upheld California’s competency procedures, ruling that due process allows a presumption of competence and permits requiring a defendant to prove incompetence by a preponderance of the evidence, evaluated under a traditions-and-fundamental-justice standard rather than a general Mathews balancing test.


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