Documente Academic
Documente Profesional
Documente Cultură
MONTANA
June 18, 1979 | Brennan, J. | Certiorari | Presumptions
PETITIONER: David Sandstrom
RESPONDENT: Supreme Court of Montana
SUMMARY: Sandstrom confessed to the killing of Annie Jessen, and was charged with deliberate homicide. His counsel argues
that since Sandstrom did not do it purposely or knowingly, he cannot be convicted of said crime. The trial court instructed the jury
that the law presumes that a person intends the ordinary consequences of his voluntary acts. Petitioner objected on the ground that
such presumption shifted the burden of proof on the defense. The Supreme Court held that such instruction was unconstitutional,
because regardless if the jury interpreted such instruction as permissive or mandatory, It cannot discount the possibility that the
jurors will actually proceed upon one or the other of those interpretations.
DOCTRINE: A state must prove every ingredient of an offense beyond a reasonable doubt, and . . . may not shift the burden of
proof to the defendant by means of such a presumption.
FACTS:
1. 18-year-old David Sandstrom confessed to the slaying of
Annie Jessen. He was charged with deliberate homicide, in
that he purposely or knowingly caused the death of Jessen.
2. At trial, Sandstroms counsel argued that his client did not
do so purposely or knowingly, and was therefore not guilty
of deliberate homicide, but of a lesser crime. This claim was
supported by the testimony of two court-appointed mental
health experts, which demonstrated that the killing was due to
a personality disorder aggravated by alcohol consumption.
3. The prosecution requested the trial judge to instruct the
jury that "the law presumes that a person intends the
ordinary consequences of his voluntary acts." Petitioner's
counsel objected, arguing that the instruction has the effect of
shifting the burden of proof on the issue of purpose or
knowledge to the defense, and that that is impermissible under
the Federal Constitution, due process of law.
4. The objection was overruled and the jury sentenced herein
petitioner to 100 years of prison.
5. Upon appeal to the Supreme Court of Montana, the latter
affirmed the Decision because the cases cited by defendant
(which prohibited shifting the burden of proof to the defendant
by means of a presumption) did not prohibit allocation of
some burden of proof.
ISSUE/S:
1. WON the judges instruction had the effect of relieving the
State of the burden of proof of petitioners state of mind
(and is therefore unconstutional) YES
RULING: The judgment of the Supreme Court of Montana is
reversed
RATIO:
1. Respondent argues that the instruction merely described a
permissive inference, but did not require the jury to draw
conclusions about a defendants intent from his actions.
2. But the Court held that, even respondent admits that it is
possible that the jury believed they were required to apply the
presumption. They were not told they had a choice, or that
they might infer such a conclusion; they were only told that
the law presumed it. A reasonable juror could easily have