Does California's heightened standard for a successive competency hearing violate the Due Process Clause of the Fourteenth Amendment?

QUESTION PRESENTED Pate v. Robinson, 383 U.S. 375, 385 (1966) and Drope v. Missouri, 420 U.S. 162, 172 (1975) require courts to provide adequate procedures to prevent a mentally incompetent criminal defendant from being tried, convicted, or sentenced in violation of the Due Process Clause. A trial court must hold an initial competency hearing if “sufficient doubt” exists as to the defendant’s present competency. Drope, 420 U.S. at 180; Dusky v. United States, 362 U.S. 402, 402 (1960). Because a defendant’s mental condition can change during the course of the proceedings, a court has a continuing responsibility to assess competency consistent with due process even after it holds an initial competency hearing. California, in conflict with at least four States, applies a heightened standard to successive competency determinations by allowing courts to rely on a prior competency finding unless it “is presented with a substantial change of circumstances or with new evidence casting a serious doubt on the validity of that finding.” People v. Rodas, 429 P.3d 1122, 1129 (Cal. 2018) (internal quotation marks omitted). The question presented is: Does California’s heightened standard for a successive competency hearing violate the Due Process Clause of the Fourteenth Amendment?