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.
References
[edit]- ^ Criminal Law Cases and Materials, Seventh Edition, 2012; John Kaplan, Robert Weisberg, Guyora Binder
External links
[edit]- Text of Sandstrom v. Montana, 442 U.S. 510 (1979) is available from: Justia Library of Congress Oyez (oral argument audio)