Sandstrom v. Montana
61 L. Ed. 2d 39 · Supreme Court of the United States · 1979
Facts
On November 22, 1976, 18-year-old David Sandstrom confessed to the slaying of Annie Jessen. Based on his confession and corroborating evidence, Sandstrom was charged with deliberate homicide, meaning he "purposely or knowingly caused the death of Annie Jessen." At trial, Sandstrom's attorney conceded the killing but argued his client did not act "purposely or knowingly" due to a personality disorder aggravated by alcohol consumption. Two court-appointed mental health experts testified about Sandstrom's mental state at the time of the incident.
Procedural history
After a jury found petitioner guilty of deliberate homicide, he was sentenced to 100 years in prison. Sandstrom appealed to the Supreme Court of Montana, arguing the instruction unconstitutionally shifted the burden of proof. The Montana Supreme Court upheld the instruction, holding it only placed a burden of production on the defendant. The U.S. Supreme Court granted certiorari to determine the instruction's constitutionality.
Issue
Does a jury instruction stating that "the law presumes that a person intends the ordinary consequences of his voluntary acts" violate the Fourteenth Amendment's requirement that the State prove every element of a criminal offense beyond a reasonable doubt, when intent is an element of the crime charged?
Holding
Yes, the jury instruction that "the law presumes that a person intends the ordinary consequences of his voluntary acts" is unconstitutional. The instruction represents constitutional error because it could be interpreted by a reasonable juror as either a conclusive presumption or a burden-shifting presumption, both of which violate due process.
Rule
The Due Process Clause requires the State to prove every element of a criminal offense beyond a reasonable doubt. A jury instruction that creates a conclusive presumption on an element of the crime, such as intent, unconstitutionally removes that element from the jury's fact-finding function and conflicts with the presumption of innocence. Similarly, an instruction that shifts the burden of persuasion on an element of the crime to the defendant violates due process. Because the challenged instruction could be interpreted by a reasonable juror in either of these unconstitutional ways, it relieves the State of its burden to prove intent beyond a reasonable doubt.
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