Teofilo Medina, JR. v. California (505 U.S. 437)

U.S. Supreme Court · decided June 22, 1992 · Supreme Court Database (Spaeth)

Citation
505 U.S. 437 · 112 S. Ct. 2572
Decided
June 22, 1992
Term
October Term 1991
Vote
7–2
Majority author
Justice Kennedy
Issue area
Due Process
Disposition
Affirmed
Outcome
Petitioning party lost
Ideological direction
Conservative

Opinion excerpt

Justice Kennedy delivered the opinion of the Court. It is well established that the Due Process Clause of the Fourteenth Amendment prohibits the criminal prosecution of a defendant who is not competent to stand trial. Drope v. Missouri, 420 U. S. 162 (1975); Pate v. Robinson, 383 U. S. 375 (1966). The issue in this case is whether the Due Process Clause permits a State to require a defendant who alleges incompetence to stand trial to bear the burden of proving so by a preponderance of the evidence. In 1984, petitioner Teofilo Medina, dr., stole a gun from a pawnshop in Santa Ana, California. In the weeks that followed, he held up two gas stations, a drive-in dairy, and a market, murdered three employees of those establishments, attempted to rob a fourth employee, and shot at two passersby who attempted to follow his getaway car. Petitioner was apprehended less than one month after his crime spree began and was charged with a number of criminal offenses, including three counts of first-degree murder. Before trial, petitioner’s counsel moved for a competency hearing under Cal. Penal Code Ann. § 1368 (West 1982), on the ground that he was unsure whether petitioner had the ability to participate in the criminal proceedings against him. 1 Record 320. Under California law, “[a] person cannot be tried or adjudged to punishment while such person is mentally incompetent.” Cal. Penal…

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