Sandstrom v. Montana

442 U.S. 510, 99 S. Ct. 2450 (1979)



The Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged.


At his jury trial in a Montana state court on a charge of deliberate homicide, in that he "purposely or knowingly" caused the death of the victim, a defendant admitted killing the victim but argued that he did not do so purposely or knowingly and was therefore not guilty of deliberate homicide but of a lesser crime. The trial judge, upon the prosecution's request, instructed the jury that the law presumed that a person intended the ordinary consequences of his voluntary acts. Defendant objected that the instruction had the effect of shifting the burden of proof on the issue of purpose or knowledge to the defense, and that such was impermissible in terms of due process of law under the Federal Constitution. After being found guilty of deliberate homicide, the defendant was sentenced to 100 years' imprisonment. On appeal, the Supreme Court of Montana affirmed the conviction. On petition for certiorari, the court reversed.


Was the instruction given by the judge during the defendant’s jury trial a violation of the due process clause?




The Court held that the jury was not told that the presumption could be rebutted by petitioner's simple presentation of some evidence, or that it could be rebutted at all. A reasonable jury could well have interpreted the presumption as conclusive, not technically as a presumption at all, but rather as an irrebuttable direction by the trial court to find intent once convinced of the facts triggering the presumption. The challenged jury instruction had the effect of relieving the State of the burden of proof on the critical question of petitioner's state of mind. Under the two possible interpretations of the challenged instruction, precisely that effect resulted, and the instruction therefore represented constitutional error. Either interpretation would have deprived petitioner of his right to due process of law.

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