Cite as: 517 U. S. 348 (1996)
Opinion of the Court
Cruzan v. Director, Mo. Dept. of Health, 497 U. S. 261, 283 (1990). For that reason, we have held that due process places a heightened burden of proof on the State in civil proceedings in which the "individual interests at stake . . . are both 'particularly important' and 'more substantial than mere loss of money.' " Santosky v. Kramer, 455 U. S. 745, 756 (1982) (termination of parental rights) (quoting Adding-ton, 441 U. S., at 424).19
Far from "jealously guard[ing]," Jacob v. New York City, 315 U. S. 752, 752-753 (1942), an incompetent criminal defendant's fundamental right not to stand trial, Oklahoma's practice of requiring the defendant to prove incompetence by clear and convincing evidence imposes a significant risk of an erroneous determination that the defendant is competent. In Medina we found no comparable risk because the presumption would affect only the narrow class of cases in which the evidence on either side was equally balanced.
19 See also Addington v. Texas (involuntary civil commitment); Woodby v. INS, 385 U. S. 276, 285-286 (1966) (deportation); Chaunt v. United States, 364 U. S. 350, 353 (1960) (denaturalization); Schneiderman v. United States, 320 U. S. 118, 125 (1943) (denaturalization).
Our opinions in Cruzan v. Director, Mo. Dept. of Health, 497 U. S. 261 (1990), and Ohio v. Akron Center for Reproductive Health, 497 U. S. 502 (1990), are not to the contrary. In Cruzan we held that the Due Process Clause does not prohibit Missouri from requiring a third party who seeks to terminate life-sustaining treatment to demonstrate by clear and convincing evidence that the incompetent person receiving such treatment would wish that step to be taken. 497 U. S., at 280. We reasoned that the heightened standard of proof was permissible because the decision-maker was a surrogate for the incompetent individual, id., at 280-281, and because the consequences of an erroneous decision were irreversible, id., at 283. In Akron Center for Reproductive Health we upheld an Ohio statute that required an unmarried, unemancipated minor woman who sought to obtain an abortion without notifying a parent to prove by clear and convincing evidence that judicial bypass of the notification requirement was appropriate in her case. We approved the heightened standard of proof in that case largely because the proceeding at issue was ex parte. 497 U. S., at 515-516.
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