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Medina v. California

United States Supreme Court
505 U.S. 437 (1992)


Facts

Medina (plaintiff) stole a gun, robbed several places, and killed three people. The state of California (defendant) charged Medina with multiple offenses, including three counts of first-degree murder. Before trial began, Medina’s lawyer moved for a competency hearing. Under California law, a person cannot participate in criminal proceedings against him if he is mentally incompetent. The California statute defining mental incompetence states that the defendant is presumed competent and that the party claiming incompetence bears the burden of proving incompetence by a preponderance of the evidence. The trial court granted Medina’s motion for a competency hearing and the jury heard conflicting expert testimony regarding Medina’s mental state before finding him competent to stand trial. Medina was convicted of all three murder charges and sentenced to death. On appeal, Medina argued that placing the burden of proof on the defendant in a competency hearing violated due process. The state supreme court affirmed his conviction. The United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Kennedy, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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Concurrence (O’Connor, J.)

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