Thursday, December 5, 2013

Sandstrom v. Montana case brief

Sandstrom v. Montana case brief summary
442 U.S. 510 (1979)

On writ of certiorari to the Supreme Court (Montana), the petitioner challenged the judgment affirming his conviction of deliberate homicide in violation of a Montana statute and the holding that an instruction, that presumed a person intended the consequences of his voluntary acts, did not violate due process standards.

Petitioner was convicted of intentional homicide in violation of a Montana statute, based on a jury instruction that the law presumed that a person intended the ordinary consequences of his voluntary acts. The Montana Supreme Court affirmed the lower court's holding and, on petition for certiorari, the court reversed.

  • The Court held that the jury was not told that the presumption could be rebutted by petitioner's simple presentation of some evidence, or that it could be rebutted at all. 
  • A reasonable jury could well have interpreted the presumption as conclusive, not technically as a presumption at all, but rather as an irrebuttable direction by the trial court to find intent once convinced of the facts triggering the presumption. 
  • The challenged jury instruction had the effect of relieving the State of the burden of proof on the critical question of petitioner's state of mind. 
  • Under the two possible interpretations of the challenged instruction, precisely that effect resulted, and the instruction therefore represented constitutional error.
The Petitioner's conviction for intentional homicide was reversed.
The jury may have interpreted the judge's instruction as constituting either a burden-shifting presumption, or a conclusive presumption.
Either interpretation would have deprived the petitioner of his right to due process of law.

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