Connecticut v. Johnson
Annotate this Case
460 U.S. 73 (1983)
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U.S. Supreme Court
Connecticut v. Johnson, 460 U.S. 73 (1983)
Connecticut v. Johnson, 460 U.S. 73 (1983)
Argued October 13, 1982
Decided February 23, 1983
460 U.S. 73
Upon a jury trial in a Connecticut state court, respondent was convicted of all the charges under a multicount information, including charges of attempted murder and robbery. The trial court's general instructions to the jury included an instruction that
"a person's intention may be inferred from his conduct and every person is conclusively presumed to intend the natural and necessary consequences of his act."
In specific instructions on the elements of each crime, the charge as to attempted murder again referred to a conclusive presumption of intent, but the instructions on robbery did not contain any further discussion of intent. While respondent's appeal was pending, this Court decided Sandstrom v. Montana, 442 U. S. 510, which held that the Due Process Clause of the Fourteenth Amendment was violated by a jury instruction that "the law presumes that a person intends the ordinary consequences of his voluntary acts," because a reasonable juror might have viewed it as creating a conclusive presumption of intent or as shifting the burden of proof as to intent. Sandstrom left open the question whether, if a jury is so instructed, the error can ever be harmless. Thereafter, the Connecticut Supreme Court, while affirming respondent's convictions on other counts in the information, reversed his convictions for attempted murder and robbery. Without discussing the State's argument that the Sandstrom violation was harmless, the court concluded that the unconstitutional "conclusive presumption" language in the general instructions was not cured by the specific instructions on attempted murder and robbery.
Held: The judgment is affirmed. 185 Conn.163, 440 A.2d 858, affirmed.
JUSTICE BLACKMUN, joined by JUSTICE BRENNAN, JUSTICE WHITE, and JUSTICE MARSHALL, concluded that the instructional error deprived respondent of "constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error," Chapman v. California, 386 U. S. 18, 386 U. S. 23. No matter how strong the prosecution's evidence, a reviewing court cannot find beyond a reasonable doubt that a Sandstrom error did not contribute to the jury's verdict. A trial judge may not direct a jury to return a guilty verdict regardless of how overwhelmingly the evidence may point in that direction, and a conclusive presumption on the issue of intent is the functional equivalent of a directed verdict on that issue. Respondent's jurors reasonably could have
interpreted the instructions as requiring a conclusive presumption on the issue of intent, an element of the crimes charged, leading them to ignore the evidence -- including evidence relating to respondent's apparent defense that he intended to borrow, rather than steal, the victim's car, and that he did not intend to kill the victim -- in finding that the State had proved respondent guilty beyond a reasonable doubt. If so, a reviewing court cannot hold that the error did not contribute to the verdict, since the fact that the reviewing court may view the evidence of intent as overwhelming is irrelevant. While there may be rare situations in which the reviewing court can be confident that a Sandstrom error did not play any role in the jury's verdict -- such as where, by raising a particular defense or by his other actions, the defendant himself has taken the issue of intent from the jury -- such an exception, regardless of its boundaries, does not apply here. Pp. 460 U. S. 81-88.
JUSTICE STEVENS concluded that no federal question was raised by the Connecticut Supreme Court's refusal to consider whether the Sandstrom error here was harmless, and that therefore the writ of certiorari should simply be dismissed. However, because a fifth vote was necessary to authorize the entry of a Court judgment, he joined the disposition allowing the Connecticut Supreme Court's judgment to stand. Pp. 460 U. S. 88-90.
BLACKMUN, J., announced the judgment of the Court, and delivered an opinion, in which BRENNAN, WHITE, and MARSHALL, JJ., joined. STEVENS, J., filed an opinion concurring in the judgment, post, p. 460 U. S. 88. BURGER, C.J., filed a dissenting opinion, post, p. 460 U. S. 90. POWELL, J., filed a dissenting opinion, in which BURGER, C.J., and REHNQUIST and O'CONNOR, JJ., joined, post, p. 460 U. S. 90.