442 U.S. 510, 99 S. Ct. 2450, 61 L. Ed. 2d 39 (1979)
David Sandstrom, an 18-year-old, confessed on November 22, 1976, to the slaying of Annie Jessen.1 Based on the confession and corroborating evidence, he was charged on December 2 with deliberate homicide under Montana law for purposely or knowingly causing her death.2
At trial, Sandstrom's attorney told the jury that although his client admitted killing Jessen, he did not do so purposely or knowingly and was therefore guilty only of a lesser crime.3 The defense relied on testimony from two court-appointed mental health experts describing Sandstrom's mental state, attributing the killing to a personality disorder aggravated by alcohol consumption.4
The prosecution requested, and over defense objection the trial judge delivered, the instruction that the law presumes a person intends the ordinary consequences of his voluntary acts.5 The jury found Sandstrom guilty of deliberate homicide, and he was sentenced to 100 years in prison.6
Sandstrom appealed to the Supreme Court of Montana, which upheld the conviction.7 The United States Supreme Court granted certiorari to review the constitutionality of the instruction.8
Whether, in a case in which intent is an element of the crime charged, the jury instruction that the law presumes that a person intends the ordinary consequences of his voluntary acts violates the Fourteenth Amendment's requirement that the State prove every element of a criminal offense beyond a reasonable doubt?9
The Due Process Clause of the Fourteenth Amendment requires the prosecution to prove every element of a criminal offense beyond a reasonable doubt.10 Jury instructions creating conclusive presumptions or presumptions that shift the burden of persuasion on an element such as intent violate this mandate.11
Yes. Sandstrom was charged with deliberate homicide requiring proof that he purposely or knowingly caused the victim's death, and intent was the sole contested element at trial.12 The trial court delivered the instruction that the law presumes a person intends the ordinary consequences of his voluntary acts. A reasonable juror could have viewed the instruction as either a conclusive direction to find intent or a direction that shifted to the defendant the burden of persuasion on that element.13
Either interpretation relieved the State of its constitutional obligation to prove intent beyond a reasonable doubt.14
The challenged jury instruction violates the Fourteenth Amendment.15
Related opinions on this issue
Justice Rehnquist concurred in the judgment while expressing reluctance to parse state jury instructions in detail.16 He noted that a single instruction to a jury may not be judged in artificial isolation but must be viewed in the context of the overall charge. He observed that if the charge had merely described a permissive inference it could not conceivably have run afoul of the constitutional decisions.17
Nevertheless he deferred to the majority's determination that a reasonable juror could have viewed the instruction as mandatory and that this distinction could have affected the jury's application of the presumption.18