Randall v. Sorrell case brief

Randall v. Sorrell case brief summary

548 U.S. 230 (2006)

CASE SYNOPSIS
Defendant was convicted of receiving a firearm while under indictment in violation of 18 U.S.C.S. § 922(n) and making false statements in connection with the acquisition of a firearm in violation of § 922(a)(6). The United States Court of Appeals for the Fifth Circuit affirmed, rejecting defendant's challenge to the jury instructions regarding proof of duress. Certiorari was granted.

CASE FACTS
Defendant admitted that, while purchasing firearms, she provided an incorrect address and falsely stated that she was not under indictment for a felony. Defendant alleged that she acted under duress because her boyfriend threatened to kill her or hurt her daughters if she did not buy the guns for him. Defendant contended that the district court's instructions to the jury erroneously required her to prove duress by a preponderance of the evidence instead of requiring the Government to prove beyond a reasonable doubt that she did not act under duress.


DISCUSSION

• The Court rejected defendant's arguments and presumed that Congress intended her to bear the burden of proving the defense of duress by a preponderance of the evidence in the context of the firearms offenses at issue. 
• The jury instructions were consistent with the Government's requirement to prove defendant's mental state under 18 U.S.C.S. §§ 922(a)(6) and 924(a)(1)(D) and, as such, did not run afoul of the Fifth Amendment's Due Process Clause when they placed the burden on defendant to establish the existence of duress. 
• Also, modern common law did not require the Government to bear the burden.

CONCLUSION
The Court affirmed the judgment of the appellate court.

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