Sandstrom v. Montana

1979

Court: US Supreme Court

Facts: Sandstrom killed a woman; not too many facts in the opinion. But he claims his mental state precluded doing so "purposely or knowingly."

Posture: Convicted at trial, affirmed by Montana Supreme Court.

Issue: If intent is an element of a crime, does the jury intruction, "the law presumes that a person intends the ordinary consequences of his voluntary acts," prejudice the defense in a way that violates the 14th Amendment requirement for proof beyond reasonable doubt?

Holding: Yes. Reversed.

Rule: This kind of language shifts both the burden of production and the burden of persuasion. That is not allowed.

Reasoning: The Montana Supreme Court is the final authority on Montana law, but not on what is constitutional.

Dicta: Rhenquist concurs, even though he doesn't want to see the Supreme Court get bogged down in arguments about jury instructions.