Sandstrom v. Montana

Supreme Court of the United States · 1979 · Criminal Law

Criminal LawDue ProcessJury InstructionsPresumptionsFourteenth AmendmentDue Processreasonable doubtpresumptions

Facts

Sandstrom was charged with deliberate homicide for purposely or knowingly causing Annie Jessen's death. At trial, he admitted killing Jessen but disputed that he acted purposely or knowingly, relying on mental health testimony about his mental state at the time of the killing. Over defense objection, the court instructed the jury that "the law presumes that a person intends the ordinary consequences of his voluntary acts." The jury returned a general verdict of guilty.

Issue

Whether, in a criminal case where intent is an element of the offense, instructing the jury that "the law presumes that a person intends the ordinary consequences of his voluntary acts" violates the Fourteenth Amendment requirement that the State prove every element of the crime beyond a reasonable doubt.

Rule

A criminal jury instruction is unconstitutional if a reasonable juror could interpret it as either a conclusive presumption or a presumption shifting the burden of persuasion to the defendant on an element of the offense. Due process requires the State to prove beyond a reasonable doubt every fact necessary to constitute the crime, and the State may not use such presumptions to relieve itself of that burden.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a homicide trial in Phoenix, Jordan Pike admits firing the shot but argues he lacked the required intent because he was in a dissociative state. The judge instructs the jury: "The law presumes that a person intends the ordinary consequences of his voluntary acts."

If intent is an element of the offense and is the main disputed issue, is the instruction constitutional?

Explanation. The instruction is unconstitutional if a reasonable juror could interpret it as either a conclusive presumption or a burden-shifting presumption on an element of the crime. Telling jurors that "the law presumes" intent, without saying they may reject it, can be understood as mandatory rather than permissive. That violates due process because the State must prove every element, including intent, beyond a reasonable doubt.