Thursday, December 5, 2013

County of Ulster v. Allen case brief

County of Ulster v. Allen case brief summary
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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1 comment:

  1. County of Ulster v. Allen case brief notes

    Presumption 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

    ReplyDelete

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