Leland v. Oregon | |
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Argued January 29, 1952 Decided June 9, 1952 | |
Full case name | Leland v. Oregon |
Citations | 343 U.S. 790 ( more ) 72 S. Ct. 1002; 96 L. Ed. 1302; 1952 U.S. LEXIS 1955 |
Case history | |
Prior | Appeal from the Supreme Court of Oregon |
Holding | |
The Court upheld the constitutionality of placing the burden of persuasion on the defendant when they argue an insanity defense in a criminal trial. | |
Court membership | |
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Case opinions | |
Majority | Clark, joined by Vinson, Reed, Douglas, Jackson, Burton, Minton |
Dissent | Frankfurter, joined by Black |
Leland v. Oregon, 343 U.S. 790 (1952), was a United States Supreme Court case in which the Court upheld the constitutionality of placing the burden of persuasion on the defendant when they argue an insanity defense in a criminal trial. [1] This differed from previous federal common law established in Davis v. United States , in which the court held that if the defense raised an insanity defense, the prosecution must prove sanity beyond a reasonable doubt, but Davis was not a United States constitutional ruling, so only limited federal cases, but not state cases. [2] : 17 Oregon had a very high burden on defense, that insanity be proved beyond a reasonable doubt. [2] : 17 At that time, twenty other states also placed the burden of persuasion on the defense for an insanity defense. [2] : 17
The defendant was convicted of killing a fifteen-year-old girl in Multnomah County. After being arrested for auto theft, the defendant asked for a homicide officer, verbally confessed to the murder, took the police to the scene of the crime, and signed a written confession. After being indicted, he then spoke to a lawyer for the first time. At trial, a jury convicted him and recommended the death penalty.
Oregon law required the defendant required proof of insanity beyond a reasonable doubt. The case claimed that the "statute in effect requires a defendant pleading insanity to establish his innocence by disproving beyond a reasonable doubt elements of the crime necessary to a verdict of guilty, and that the statute is therefore violative of that due process of law secured by the Fourteenth Amendment."