Sandstrom v. Montana
Annotate this Case
442 U.S. 510 (1979)
U.S. Supreme Court
Sandstrom v. Montana, 442 U.S. 510 (1979)
Sandstrom v. Montana
Argued April 18, 1979
Decided June 18, 1979
442 U.S. 510
Based upon a confession and other evidence, petitioner was charged under a Montana statute with "deliberate homicide," in that he "purposely or knowingly" caused the victim's death. At trial, petitioner argued that, although he killed the victim, he did not do so "purposely or knowingly," and therefore was not guilty of deliberate homicide. The trial court instructed the jury that "[t]he law presumes that a person intends the ordinary consequences of his voluntary acts," over petitioner's objection that such instruction had the effect of shifting the burden of proof on the issue of purpose or knowledge. The jury found petitioner guilty, and the Montana Supreme Court affirmed, holding that although shifting the burden of proof to the defendant by means of a presumption is prohibited, allocation of "some burden of proof" to a defendant is permissible. Finding that under the instruction in question petitioner's sole burden was to produce "some" evidence that he did not intend the ordinary consequences of his voluntary acts, and not to disprove that he acted "purposely or knowingly," the Montana court held that the instruction did not violate due process standards.
Held: Because the jury may have interpreted the challenged presumption as conclusive, like the presumptions in Morissette v. United States, 342 U. S. 246, and United States v. United States Gypsum Co., 438 U. S. 422, or as shifting the burden of persuasion, like that in Mullaney v. Wilbur, 421 U. S. 684, and because either interpretation would have violated the Fourteenth Amendment's requirement that the State prove every element of a criminal offense beyond a reasonable doubt, the instruction is unconstitutional. Pp. 442 U. S. 514-527.
(a) The effect of a presumption in a jury instruction is determined by the way in which a reasonable juror could have interpreted it, not by a state court's interpretation of its legal import. Pp. 442 U. S. 514, 442 U. S. 517.
(b) Conclusive presumptions
"conflict with the overriding presumption of innocence with which t,he law endows the accused and which extends to every element of the crime,"
Morissette, supra at 342 U. S. 275, and they "invad[e the] factfinding function," United States Gypsum Co. supra at 438 U. S. 446, which, in a criminal case, the law assigns to the jury. The presumption announced to petitioner's jury may well have had exactly
these consequences, since upon finding proof of one element of the crime (causing death), and of facts insufficient to establish the second (the voluntariness and "ordinary consequences" of petitioner's action), the jury could have reasonably concluded that it was directed to find against petitioner on the element of intent. The State was thus not forced to prove "beyond a reasonable doubt . . . every fact necessary to constitute the crime . . . charged," In re Winship, 397 U. S. 358, 397 U. S. 364, and petitioner was deprived of his constitutional rights. Pp. 442 U. S. 521-523.
(c) A presumption which, although not conclusive, had the effect of shifting the burden of persuasion to petitioner, would have suffered from similar infirmities. If the jury interpreted the presumption in this manner, it could have concluded that, upon proof by the State of the slaying, and of additional facts not themselves establishing the element of intent, the burden was then shifted to petitioner to prove that he lacked the requisite mental state. Such a presumption was found constitutionally deficient in Mullaney, supra. P. 442 U. S. 524.
(d) Without merit is the State's argument that, since the jury could have interpreted the word "intends" in the instruction as referring only to petitioner's "purpose," and could have convicted petitioner solely for his "knowledge" without considering "purpose," it might not have relied upon the tainted presumption at all. First, it is not clear that a jury would have so interpreted "intends." More significantly, even if a jury could have ignored the presumption, it cannot be certain that this is what it did do, as its verdict was a general one. Pp. 442 U. S. 525-526.
(e) Since whether the jury's reliance upon the instruction constituted, or could have ever constituted, harmless error are issues that were not considered by the Montana Supreme Court, this Court will not reach them as an initial matter. Pp. 442 U. S. 526-527.
176 Mont. 492, 580 P.2d 106, reversed and remanded.
BRENNAN, J., delivered the opinion for a unanimous Court. REHNQUIST, J., filed a concurring opinion, in which BURGER, C.J., joined, post, p. 442 U. S. 527.
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