Sandstrom v. Montana Case Brief

Why is the case important?

Appellant was convicted of murder. Appellant contends that the jury instruction offered presented an irrebuttable presumption of guilt.

Facts of the case

Question

Whether a jury instruction stating that the law presumes intent from the ordinary consequences of voluntary acts is a violation of 14th Amendment of the Constitution of the United States requiring the State to prove every element of an offense beyond a reasonable doubt.

Answer

The instruction in this case is unconstitutional.
The Due Process Clause of the Constitution protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged.

Conclusion

The Court held that the jury was not told that the presumption could be rebutted by petitioner’s simple presentation of some evidence, or that it could be rebutted at all. A reasonable jury could well have interpreted the presumption as conclusive, not technically as a presumption at all, but rather as an irrebuttable direction by the trial court to find intent once convinced of the facts triggering the presumption. The challenged jury instruction had the effect of relieving the State of the burden of proof on the critical question of petitioner’s state of mind. Under the two possible interpretations of the challenged instruction, precisely that effect resulted, and the instruction therefore represented constitutional error. Either interpretation would have deprived petitioner of his right to due process of law.

  • Case Brief: 1979
  • Petitioner: Sandstrom
  • Respondent: Montana
  • Decided by: Burger Court

Citation: 442 US 510 (1979)
Argued: Apr 18, 1979
Decided: Jun 18, 1979