Facts
- David Sandstrom, age 18, was charged under Montana law with deliberate homicide, requiring proof that he killed “purposely or knowingly.”
- Sandstrom admitted causing the victim’s death but contested the required mental state.
- Over objection, the trial court instructed the jury: “The law presumes that a person intends the ordinary consequences of his voluntary acts.”
- The jury convicted Sandstrom of deliberate homicide.
- The Montana Supreme Court affirmed, treating the instruction as imposing only a burden of production on the defendant.
- The U.S. Supreme Court granted certiorari.
Issues
- Whether a jury instruction that “the law presumes that a person intends the ordinary consequences of his voluntary acts” violates the Fourteenth Amendment by allowing jurors to treat intent as conclusively established or by shifting to the defendant the burden of persuasion on intent.
Decision
-
The Supreme Court reversed the Montana Supreme Court.
-
The Court held the instruction unconstitutional because a reasonable juror could interpret it as:
- a conclusive presumption requiring a finding of intent once a voluntary act and its ordinary consequences are found, or
- a presumption shifting the burden of persuasion on intent to the defendant.
-
Either interpretation would relieve the State of proving the intent element beyond a reasonable doubt, violating due process.
Legal Principles
- Due process requires the prosecution to prove beyond a reasonable doubt every element of the charged offense, including mens rea.
- The constitutional effect of a presumption in a jury instruction is evaluated by how a reasonable juror could understand it, not by an appellate court’s later characterization.
- Jury instructions that can be read as creating a conclusive presumption on an element, or that shift the burden of persuasion on an element to the defendant, violate the Fourteenth Amendment.
Conclusion
Because the challenged intent instruction could reasonably be understood to compel a finding of intent or to require the defendant to disprove intent, it impermissibly reduced the State’s burden of proof on an essential element and required reversal.