LOCATION: Nathan Bishop Middle School
DOCKET NO.: 90-8370
DECIDED BY: Rehnquist Court (1991-1993)
LOWER COURT: Supreme Court of California
CITATION: 505 US 437 (1992)
ARGUED: Feb 25, 1992
DECIDED: Jun 22, 1992
Holly D. Wilkens - on behalf of the Respondent
Michael Pescetta - on behalf of the Petitioner
Facts of the case
A person who should hold criminal responsibility must be sane, while the duty of proving a violation of the mental state is the responsibility of the defendant and his lawyer. This rule was once again confirmed in the framework of the case brief Medina v. California.
The basis for insanity may be dementia, a temporary or chronic mental disorder, as well as a morbid mental state. By law, a citizen who was in a deranged state at the time of the commission of a crime is not criminally responsible for his crime. In this case study, Medina was accused of robbing and killing three people. During the hearing, he argued that the duty to prove the violation of his mental state was contrary to his rights in the process as a defendant.
In order to prosecute the defendant, it is necessary to establish three facts pertaining to consciousness (the presence of consciousness is the ability to realize, the volume and clarity is the ability to fully realize, the level of development is the ability to realize social consequences), and also listen to the opinion of the psychologist and psychiatrist for whom the phenomenon of consciousness in a person's life occurs much earlier than the lawyer begins to take it into account. In this case, the accused was found to be mentally healthy and fully sane, and thus, the court imposed a sentence of life imprisonment. The rule that the duty of confirming one's mental state is superimposed on the accused in the process was confirmed by the Supreme Court.
Media for Medina v. CaliforniaAudio Transcription for Oral Argument - February 25, 1992 in Medina v. California
Audio Transcription for Opinion Announcement - June 22, 1992 in Medina v. California
William H. Rehnquist:
The opinions of the Court in two cases will be announced by Justice Kennedy.
Anthony M. Kennedy:
The first case is Medina versus California, No. 90-8370.
The case comes to us on a writ of certiorari to the Supreme Court of the State of California.
In 1984, Medina, who is the petitioner in this case, went on a crime spree and committed several robberies, he murdered three persons and was tried on three counts of first degree murder as well as a number of lesser offenses.
Before trial, Medina's counsel moved for a hearing to determine whether he was mentally competent to stand trial.
At the conclusion of the hearing, the Trial Court instructed the jury under the California Penal Code that a criminal defendant is presumed to be competent and that Medina had the burden of proving that he was incompetent by a preponderance of the evidence.
The jury found Medina competent to stand trial and in a subsequent trial proceeding, he was convicted and sentenced to death.
On appeal, Medina argues that the Penal Code violated his right to due process by placing the burden of proof on him to establish that he was not competent to stand trial and by establishing the presumption that he was competent to stand trial unless proven otherwise.
The California Supreme Court rejected these arguments.
We granted certiorari in a decision filed today, we affirm.
As an initial matter, we reject Medina's argument that his due process challenge to the Penal Code should be analyzed under the three-factor balancing test set forth in Mathews versus Eldridge.
In our view, Mathews did not provide the appropriate framework for assessing the validity of state procedural rules which like the one at bar are part of the criminal process.
In the field of criminal law, we have defined the category of due process violations in a narrow way.
The Bill of Rights speaks in explicit terms to many aspects of criminal procedure.
Expansion of those constitutional guarantees under the open-ended rubric of the Due Process Clause invites undue interference with both considered legislative judgments and the careful balance of the Constitution strikes between liberty and order.
Furthermore, although we have invoked Mathews in resolving due process claims in two criminal law cases, the United States versus Raddatz, and Ake versus Oklahoma, it is not at all clear that Mathews was essential to the results reached in those decisions.
In our view, the proper analytic approach is that set forth in Patterson versus New York.
In Patterson, we have recognized that it is normally within the power of the state to regulate procedures under which its criminal laws had carried out, including the burden of producing evidence ad burden of persuasion.
And we sated that the state's decision in this regard is not subject to prescription 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.
Based on our review of the historical treatment the burden of proof in competency proceedings, the operation of the challenge rule, and our precedents, we cannot say that the allocation of the burden of proof to a criminal defendant to prove incompetence violates a recognized principle of justice that can be deemed fundamental.
With regard to the presumption of competence imposed by the California Penal code, we seem no reason to distrub the California Supreme Court's conclusion that in essence the challenge presumption is a restatement of the burden of proof.
In light of our determination that the allocation of the burden of proof to the defendant does not violate due process, it follows that this aspect of the statute also withstands scrutiny.
Justice O'Connor has filed an opinion concurring in the judgment in which Justice Souter has joined; Justice Blackmun has a filed a dissenting opinion in which Justice Stevens has joined.