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Criminal Procedure Keyed to Allen
Medina v. California
Citation:
505 U.S. 437 (1992)Facts
The Petitioner, Teofilo Medina, stole a gun from a pawnshop. Over a course of several weeks, he then held up two gas stations, a drive-in, and murdered three employees of those two establishments. He also attempted to rob a fourth employee and shot at two bystanders. The Petitioner was charged with various criminal offenses including three counts of first-degree murder. Prior to trial, the Petitioner’s counsel moved for a competency hearing on the ground that he was not sure whether the Petitioner had the ability to participate in those criminal proceedings against him. Under California law, a mentally incompetent person cannot be tried or adjudged to punishment. A person is mentally incompetent if they are unable to understand the nature of the criminal proceedings or to assist counsel in the conduct of a defense in a rational matter as a result of a mental disorder or developmental disability. California law presumes a defendant is competent and the party claiming incompetence bears the burden of proof in showing that the defendant is incompetent by the preponderance of the evidence. The jury found the Petitioner to be competent. The Petitioner was then convicted of all three first-degree murder charges. He was then sentenced to death.
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