Sandstrom v. Montana
442 U.S. 510 (1979)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A jury instruction stating that 'the law presumes that a person intends the ordinary consequences of his voluntary acts' violates the Fourteenth Amendment's Due Process Clause because a reasonable juror could interpret it as a conclusive presumption or as a burden-shifting presumption, both of which unconstitutionally relieve the State of its burden to prove every element of a criminal offense beyond a reasonable doubt.
Facts:
- On November 22, 1976, 18-year-old David Sandstrom killed Annie Jessen.
- Sandstrom subsequently confessed to the killing.
- At trial, Sandstrom did not dispute that he killed Jessen.
- Sandstrom's sole defense was that he did not act 'purposely or knowingly,' which was a required mental state for the charge of 'deliberate homicide'.
- The defense presented testimony from two court-appointed mental health experts regarding Sandstrom's mental state.
- The expert testimony suggested that due to a personality disorder aggravated by alcohol consumption, Sandstrom did not possess the requisite intent for deliberate homicide.
Procedural Posture:
- David Sandstrom was charged with 'deliberate homicide' in a Montana trial court.
- At trial, Sandstrom's counsel objected to a proposed jury instruction on the presumption of intent, arguing it unconstitutionally shifted the burden of proof.
- The trial judge overruled the objection and delivered the instruction to the jury.
- The jury found Sandstrom guilty of deliberate homicide, and he was sentenced to 100 years in prison.
- Sandstrom, as appellant, appealed to the Supreme Court of Montana, challenging the constitutionality of the jury instruction.
- The Supreme Court of Montana, with the State as appellee, affirmed the conviction, holding that the instruction only shifted the burden of production and did not violate due process.
- The United States Supreme Court granted Sandstrom's petition for a writ of certiorari.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a jury instruction stating that 'the law presumes that a person intends the ordinary consequences of his voluntary acts' violate the Fourteenth Amendment's Due Process Clause by relieving the State of its burden to prove every element of a criminal offense beyond a reasonable doubt?
Opinions:
Majority - Mr. Justice Brennan
Yes, the jury instruction violates the Fourteenth Amendment's Due Process Clause. A jury instruction is unconstitutional if a reasonable juror could have interpreted it in a way that undermines the State's burden to prove every element of the crime beyond a reasonable doubt. The instruction that 'the law presumes that a person intends the ordinary consequences of his voluntary acts' could have been interpreted by Sandstrom's jury in two unconstitutional ways. First, as a 'conclusive presumption,' which would direct the jury to find intent once it was convinced of the underlying facts, thereby taking the issue of intent away from the jury in violation of principles from Morissette and United States Gypsum Co.. Second, it could have been interpreted as shifting the burden of persuasion to the defendant to prove he lacked intent, which is unconstitutional under Mullaney v. Wilbur. Because a reasonable juror could have applied either of these unconstitutional interpretations, the instruction is invalid and deprived the defendant of due process.
Concurring - Mr. Justice Rehnquist
Yes. While expressing doubt that a jury would parse the legal distinction between 'infer' and 'presume,' the instruction could have been viewed as mandatory by a reasonable juror. A trial court's instructions must be viewed in their overall context, but the mandatory language of 'the law presumes' creates a sufficient risk of juror confusion. Given that even the State's counsel conceded it was 'possible' the jury felt required to apply the presumption, and deferring to the majority's judgment that this possibility was critical, the instruction was unconstitutional.
Analysis:
This case significantly reinforces the principle from In re Winship that the prosecution must prove every element of a crime beyond a reasonable doubt. It establishes that the constitutionality of a jury instruction involving a presumption depends on how a 'reasonable juror' could have interpreted it, not necessarily on its technical legal meaning under state law. The decision invalidates instructions that create mandatory presumptions (either conclusive or burden-shifting) on the element of intent, thereby protecting the jury's fact-finding role and the defendant's presumption of innocence. This ruling forces trial courts to use extremely precise language, favoring permissive inferences (e.g., 'you may infer') over mandatory presumptions (e.g., 'the law presumes') to avoid unconstitutionally shifting the burden of proof.
