County Court of Ulster Cty. v. Allen
99 S.Ct. 2213 · Supreme Court of the United States · 1979
Facts
Four individuals, three adult males (respondents) and a 16-year-old girl (Jane Doe), were stopped for speeding on the New York Thruway. Police discovered two loaded handguns in an open handbag on the front passenger seat, which Jane Doe admitted was hers. A machinegun and heroin were also found in the car's trunk after police pried it open. The car had been borrowed, and two occupants had reportedly placed items in the trunk earlier. The jury convicted all four of possessing the handguns but acquitted them of possessing the trunk's contents. The trial court overruled defense objections to the introduction of the handguns, relying on a New York statute that creates a presumption of possession for firearms in a vehicle by all occupants.
Procedural history
After their convictions were affirmed by the Appellate Division and the New York Court of Appeals (which summarily rejected the constitutional challenge), respondents filed a petition for a writ of habeas corpus in the U.S. District Court for the Southern District of New York. The District Court issued the writ, finding the presumption unconstitutional as applied. The Court of Appeals for the Second Circuit affirmed, but on different grounds, holding the statute unconstitutional "on its face." The Supreme Court granted certiorari to review these holdings and the constitutionality of the statute as applied to respondents.
Issue
1. Did the District Court have jurisdiction to entertain respondents' claim that the New York statutory presumption of possession is unconstitutional? 2. Was it proper for the Court of Appeals to decide the facial constitutionality of the statute? 3. Is the application of the New York statutory presumption of possession unconstitutional as applied to the respondents in this case?
Holding
1. Yes, the District Court had jurisdiction. 2. No, it was improper for the Court of Appeals to decide the facial constitutionality. 3. No, the application of the presumption was not unconstitutional in this case. The judgment of the Court of Appeals is reversed.
Rule
In criminal cases, the constitutional validity of an evidentiary device, such as a statutory presumption, depends on whether it undermines the factfinder's responsibility to find ultimate facts beyond a reasonable doubt. A permissive inference or presumption, which allows but does not require the trier of fact to infer an elemental fact from a basic fact, is valid if there is a "rational connection" between the proved fact and the inferred fact, meaning the latter is "more likely than not to flow from" the former. This type of presumption is challenged "as applied" to the specific facts. A mandatory presumption, which requires the trier of fact to find the elemental fact upon proof of the basic fact (unless rebutted), is generally examined "on its face" and must satisfy the "beyond a reasonable doubt" standard if it is the sole evidence of an element. If a presumption is permissive and not the sole basis for guilt, it only needs to satisfy the "more likely than not" test.
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