County of Ulster v. Allen case brief summary
442 U.S. 140 (1979)
CASE FACTS
Respondents were jointly tried on weapon and drug charges. Respondents objected to introduction of the weapons and drugs into evidence, but the trial court overruled respondents' objection, relying on the presumption of possession created by N.Y. Penal Law § 265.15(3). Respondents moved to dismiss the charges. The trial court denied respondents' motion, and respondents were found guilty. Respondents filed a post-trial motion challenging the constitutionality of N.Y. Penal Law § 265.15(3), which was denied and affirmed on review. Respondents filed a petition for writ of habeas corpus, contending that they were denied due process of law by application of the statutory presumption of possession. The statute was held unconstitutional, and a writ of certiorari was granted.
DISCUSSION
CONCLUSION
The Court reversed the judgment for the State, found that the habeas corpus proceeding was improper for determining constitutionality of the presumption statute, and the application of the statutory presumption was not unconstitutional. The Court held that the state statute created a permissive presumption, and the record established respondents' guilt beyond a reasonable doubt.
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442 U.S. 140 (1979)
CASE SYNOPSIS
The State sought a writ of certiorari
from an order of the United States Court of Appeals for the Second
Circuit holding that N.Y. Penal Law § 265.15(3) was
unconstitutional as applied in respondents' criminal cases. The State
asserted that it was improper for the court of appeals to decide the
facial constitutionality issue, and application of the permissive
presumption was constitutional.CASE FACTS
Respondents were jointly tried on weapon and drug charges. Respondents objected to introduction of the weapons and drugs into evidence, but the trial court overruled respondents' objection, relying on the presumption of possession created by N.Y. Penal Law § 265.15(3). Respondents moved to dismiss the charges. The trial court denied respondents' motion, and respondents were found guilty. Respondents filed a post-trial motion challenging the constitutionality of N.Y. Penal Law § 265.15(3), which was denied and affirmed on review. Respondents filed a petition for writ of habeas corpus, contending that they were denied due process of law by application of the statutory presumption of possession. The statute was held unconstitutional, and a writ of certiorari was granted.
DISCUSSION
- The Court reversed the judgment for the State, finding that that it was improper in the habeas corpus proceeding to determine the constitutionality of the statute, and the application of the statutory presumption of possession was not unconstitutional.
- The Court held that N.Y. Penal Law § 265.15(3) created a permissive presumption, and the record as a whole established respondents' guilt beyond a reasonable doubt.
CONCLUSION
The Court reversed the judgment for the State, found that the habeas corpus proceeding was improper for determining constitutionality of the presumption statute, and the application of the statutory presumption was not unconstitutional. The Court held that the state statute created a permissive presumption, and the record established respondents' guilt beyond a reasonable doubt.
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County of Ulster v. Allen case brief notes
ReplyDeletePresumption of common possession of weapons and drugs found in car
But, can’t convict on only presumption
Need something more plus presumption
Policy issues
You are aggregating dependant facts to reach BRD
Inefficient case by case analysis
No way to separate the strength of presumption and strength of evidence
Can’t use “resumption” rebutted” Francis v. Franklin
Makes it look like burden of persuasion is on Defendant
Confuses jury
Harmless Error for presumption jury charges Rose v. Clark
Evidence in this case was so overwhelming that it couldn’t have made rational difference that jury instruction was improper, so harmless error
Policy Issues
Looks like a Directed Verdict
Taking power away from the Jury
Due Process problems for cases where there is less evidence
many states have adopted dissenting rules