finding constitutional violation notwithstanding fact that charge, in addition to telling jury that “[t]he law presumes that a person intends the ordinary consequences of his voluntary acts,” instructed jury (see Petitioner’s Appendix at 36) that “[p]urpose and knowledge are manifested by the circumstances connected with the offense . . . [and] need not be proved by direct evidence, but may be inferred from acts, conduct, and circumstances appearing in evidence”
How later courts described this case
- finding constitutional violation notwithstanding fact that charge, in addition to telling jury that “[t]he law presumes that a person intends the ordinary consequences of his voluntary acts,” instructed jury (see Petitioner’s Appendix at 36) that “[p]urpose and knowledge are manifested by the circumstances connected with the offense . . . [and] need not be proved by direct evidence, but may be inferred from acts, conduct, and circumstances appearing in evidence”
- holding that a jury instruction which stated “the law presumes that a person intends the ordinary consequences of his voluntary acts” violated the Due Process Clause of the Fourteenth Amendment when used in a “deliberate” murder case because -the jury could have believed that the instruction relieved the State of Montana of having to prove the intent element of the murder charge beyond a reasonable doubt and shifted the burden to the defendant to disprove intent
- finding a jury instruction unconstitutional after noting “Sandstrom’s jurors were told that ‘[t]he law presumes that a person intends the ordinary consequences of his voluntary acts.’ They were not told that they had a choice, or that they might infer that conclusion; they were told only that the law presumed it. It is clear that a reasonable juror could easily have viewed such an instruction as mandatory”
- concluding that jury instruction stating that “the law presumes that a person intends the ordinary consequences of his voluntary acts” violates the Fourteenth Amendment by relieving the State of its burden of proof as to a defendant’s state of mind (internal quotation marks omitted)
Written by the judges who cited it.
Distinguished
Distinguished by Moore v. Mitchell, 531 F. Supp. 2d 845 (2008)
442 U.S. 510, 99 S.Ct. 2450, 61 L.Ed.2d 39 (1979), a case relied upon by Petitioner Moore, was distinguishable.
Distinguished by State v. Burkhart, 325 Mont. 27 (2004)
Thus, Sandstrom is inapposite: we are not considering a conclusive presumption of mens rea.
Distinguished by Conte v. Henderson, 534 F. Supp. 561 (1982)
The ruling of Sandstrom is clearly distinguishable when the instructions are read as a whole, and federal habeas corpus relief is not warranted.
Distinguished by State v. Alfaro, 127 Ariz. 578 (1980)
Sandstrom v. Montana, 442 U.S. 510, 99 S.Ct. 2450 (1979), cited by appellant, is inapplicable as it deals with conclusive presumptions rather than permissive inferences.
The opinion
Me. Justice Rehnquist,
with whom The Chief Justice joins,
concurring.
The Fourteenth Amendment to the United States Constitution prohibits any State from depriving a person of liberty without due process of law, and in Mullaney v. Wilbur, 421 U. S. 684 (1975), this Court held that the Fourteenth Amendment’s guarantees prohibit a State from shifting to the defendant the burden of disproving an element of the crime charged. I am loath to see this Court go into the business of parsing jury instructions given by state trial courts, for as we have consistently recognized, “a single instruction to a jury may not be judged in artificial isolation, but must be viewed in the context of the overall charge.” Cupp v. Naughten, 414 U. S. 141, 146-147 (1973). And surely if this charge had, in the words of the Court, “merely described a permissive inference,” ante, at 514, it could not conceivably have run afoul of the constitutional decisions cited by the Court in its opinion. But a majority of my Brethren conclude that “it is clear that a reasonable juror could easily have viewed such an instruction as mandatory,” ante, at 515, and counsel for the State admitted in oral argument “that 'it’s possible’ that the jury believed they were required to apply the presumption.” Ante, at 514-515.
*528 While I continue to have doubts as to whether this particular jury was so attentively attuned to the instructions of the trial court that it divined the difference recognized by lawyers between “infer” and “presume,” I defer to the judgment of the majority of the Court that this difference in meaning may have been critical in its effect on the jury. I therefore concur in the Court’s opinion and judgment.