Medina v. California case brief summary
505 U.S. 437 (1992)
CASE FACTS
Petitioner criminal defendant argued that his rights under the Due Process Clause, U.S. Constitutional Amendment V, were violated when the burden to prove incompetency was placed on petitioner by preponderance of the evidence.
DISCUSSION
CONCLUSION
The Court affirmed, holding that petitioner had the burden to establish the defense of incompetence and that burden did not offend his rights under the Due Process Clause. The State's procedures, including the requirement that petitioner establish incompetence by preponderance of the evidence, were constitutionally adequate under the Due Process Clause.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
505 U.S. 437 (1992)
CASE SYNOPSIS
Petitioner sought review of the order
of the Supreme Court of California denying petitioner's motion that
his rights under the Due Process Clause, U.S. Constitutional
Amendment V, were violated byCal. Penal Code Ann. § 1369(f) in
his criminal conviction.CASE FACTS
Petitioner criminal defendant argued that his rights under the Due Process Clause, U.S. Constitutional Amendment V, were violated when the burden to prove incompetency was placed on petitioner by preponderance of the evidence.
DISCUSSION
- The Court affirmed, holding that respondent State's procedures were adequate to protect against due process violations because only the most basic procedural safeguards were required.
- It was within the State's power to regulate the burden of production and persuasion in trials, and based on historical and precedential treatment, the State did not offend due process.
- An indigent criminal defendant was entitled only to the minimum assistance necessary to present his defense of incompetence.
- Petitioner raised the incompetency defense and had better access to evidence establish it than the State did to establish that petitioner was competent.
- The preponderance of the evidence standard was sufficient to meet due process requirements.
CONCLUSION
The Court affirmed, holding that petitioner had the burden to establish the defense of incompetence and that burden did not offend his rights under the Due Process Clause. The State's procedures, including the requirement that petitioner establish incompetence by preponderance of the evidence, were constitutionally adequate under the Due Process Clause.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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