Law School Case Brief
Leland v. Oregon - 343 U.S. 790, 72 S. Ct. 1002 (1952)
Or. Comp. Laws § 26-929 (1940) provides: When the commission of the act charged as a crime is proven, and the defense sought to be established is the insanity of the defendant, the same must be proven beyond a reasonable doubt.
In a criminal prosecution in an Oregon state court on an indictment for murder in the first degree, defendant pleaded not guilty and gave notice of his intention to prove insanity. Oregon statutes required him to prove his insanity beyond a reasonable doubt. Furthermore, the statutes did not make “morbid propensity” a defense. Defendant was found guilty by a jury and was sentenced to death. Thereafter, defendant appealed, alleging violation of his due process rights. According to the defendant, other states only required preponderance of evidence or similar measure of persuasion to establish insanity.
Was the State of Oregon’s requirement that a defendant prove his insanity beyond reasonable doubt a violation of the defendant’s right to due process?
The U.S. Supreme Court affirmed the conviction, holding that the State of Oregon’s requirement that a defendant prove that he was insane beyond a reasonable doubt was not a violation of his due process rights. According to the Court, the fact that many other states did not require such a high burden of proof was not conclusive as to whether the practice at issue accorded with due process. Rather, the Court had to consider whether the required burden of proof offended some principle of justice so rooted in the traditions and conscience of the people as to be ranked as fundamental. The Court found no such offense.
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