Does a state have a right to be free from the burden of proof in a retrospective state competency hearing?

Although there is no federal right to be free from the burden of proof in a retrospective state competency hearing, Medina, --- U.S. at ----, 112 S.Ct. at 2579, Moran contends that Nevada has created a federally protected state liberty interest in such a right. It is "well established that state laws can create liberty interests triggering federally enforceable procedural rights." Dix v. County of Shasta, 963 F.2d 1296, 1299 (9th Cir.1992). "Misapplication of these laws that lead to deprivations of those liberty interests by state institutions may be reviewed in federal habeas proceedings." Ballard v. Estelle, 937 F.2d 453, 456 (9th Cir.1991).