Sandstrom v. Montana | |
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Argued April 18, 1979 Decided June 18, 1979 | |
Full case name | David Sandstrom v. Montana |
Docket no. | 78-5384 |
Citations | 442 U.S. 510 ( more ) 99 S. Ct. 2450; 61 L. Ed. 2d 39 |
Holding | |
The Fourteenth Amendment requires that a state must prove every element of a criminal offense beyond a reasonable doubt, and may not shift the burden of proof to the defendant by means of a presumption of intent. | |
Court membership | |
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Case opinions | |
Majority | Brennan, joined by unanimous |
Concurrence | Rehnquist, joined by Burger |
Sandstrom v. Montana, 442 U.S. 510 (1979), is a United States Supreme Court case that reaffirmed the prosecution's burden of proof of the mental element of a crime by striking down a jury instruction that "the law presumes that a person intends the ordinary consequences of his voluntary acts". [1] In Francis v. Franklin , 471 U.S. 307 (1985), Justice Brennan wrote about "Sandstrom and the wellspring due process principal from which it is drawn" as follows:
Sandstrom v. Montana made clear that the Due Process Clause of the Fourteenth Amendment prohibits a State from making use of jury instructions that have the effect of relieving the State of the burden of proof on the critical question of intent in a criminal prosecution.
The insanity defense, also known as the mental disorder defense, is an affirmative defense by excuse in a criminal case, arguing that the defendant is not responsible for their actions due to a psychiatric disease at the time of the criminal act. This is contrasted with an excuse of provocation, in which the defendant is responsible, but the responsibility is lessened due to a temporary mental state. It is also contrasted with the justification of self defense or with the mitigation of imperfect self-defense. The insanity defense is also contrasted with a finding that a defendant cannot stand trial in a criminal case because a mental disease prevents them from effectively assisting counsel, from a civil finding in trusts and estates where a will is nullified because it was made when a mental disorder prevented a testator from recognizing the natural objects of their bounty, and from involuntary civil commitment to a mental institution, when anyone is found to be gravely disabled or to be a danger to themself or to others.
Jury instructions, also known as charges or directions, are a set of legal guidelines given by a judge to a jury in a court of law. They are an important procedural step in a trial by jury, and as such are a cornerstone of criminal process in many common law countries.
In a legal dispute, one party has the burden of proof to show that they are correct, while the other party had no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts needed to satisfy all the required legal elements of the dispute.
The presumption of innocence is a legal principle that every person accused of any crime is considered innocent until proven guilty. Under the presumption of innocence, the legal burden of proof is thus on the prosecution, which must present compelling evidence to the trier of fact. If the prosecution does not prove the charges true, then the person is acquitted of the charges. The prosecution must in most cases prove that the accused is guilty beyond a reasonable doubt. If reasonable doubt remains, the accused must be acquitted. The opposite system is a presumption of guilt.
Beyond (a) reasonable doubt is a legal standard of proof required to validate a criminal conviction in most adversarial legal systems. It is a higher standard of proof than the standard of balance of probabilities commonly used in civil cases because the stakes are much higher in a criminal case: a person found guilty can be deprived of liberty, or in extreme cases, life, as well as suffering the collateral consequences and social stigma attached to a conviction. The prosecution is tasked with providing evidence that establishes guilt beyond a reasonable doubt in order to get a conviction; albeit prosecution may fail to complete such task, the trier-of-fact's acceptance that guilt has been proven beyond a reasonable doubt will in theory lead to conviction of the defendant. A failure for the trier-of-fact to accept that the standard of proof of guilt beyond a reasonable doubt has been met thus entitles the accused to an acquittal. This standard of proof is widely accepted in many criminal justice systems, and its origin can be traced to Blackstone's ratio, "It is better that ten guilty persons escape than that one innocent suffer."
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Virginia v. Black, 538 U.S. 343 (2003), was a landmark decision of the Supreme Court of the United States in which the Court held, 5–4, that any state statute banning cross burning on the basis that it constitutes prima facie evidence of intent to intimidate is a violation of the First Amendment to the Constitution. Such a provision, the Court argued, blurs the distinction between proscribable "threats of intimidation" and the Ku Klux Klan's protected "messages of shared ideology". In the case, three defendants were convicted in two separate cases of violating a Virginia statute against cross burning. However, cross-burning can be a criminal offense if the intent to intimidate is proven. It was argued by former Solicitor General of Virginia, William Hurd.
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In re Winship, 397 U.S. 358 (1970), was a United States Supreme Court decision that held that "the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged." It established this burden in all cases in all states. The decision did not specify which facts constitute the charged crime.
Dixon v. United States, 548 U.S. 1 (2006), was a United States Supreme Court case concerning the level of proof required to establish the affirmative defense of duress in a federal criminal case.
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Patterson v. New York, 432 U.S. 197 (1977), was a legal case heard by the Supreme Court of the United States that stated that the Due Process Clause Fourteenth Amendment did not prevent the burdening of a defendant to prove the affirmative defense of extreme emotional disturbance as defined by law in the state of New York.
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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. 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. Oregon had a very high burden on defense, that insanity be proved beyond a reasonable doubt. At that time, twenty other states also placed the burden of persuasion on the defense for an insanity defense.
Evidential burden or "production burden" is the obligation to produce evidence to properly raise an issue at trial. Failure to satisfy the evidential burden means that an issue cannot be raised at a court of law.
The United States Constitution contains several provisions regarding the law of criminal procedure.
Francis v. Franklin, 471 U.S. 307 (1985), is a United States Supreme Court decision reaffirming due process principles elucidated in Sandstrom v. Montana, that the prosecution bears the burden of proof of establishing the mental element of intent. Justice Brennan wrote that under the Due Process Clause of the Fourteenth Amendment, a jury instruction saying that "a person of sound mind is presumed to intend the natural and probable consequences of his acts, but the presumption may be rebutted" is unconstitutional, because it shifted the burden of proof is shifted from the prosecution to the defense.